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6065. There can be no meaningful administrative
hearing until respondent provides petitioners with the
requested information, and until that time, petitioner
will disagree with all of the adjustments.
After the filing of respondent’s motions, the Court issued
orders providing the respective petitioners an opportunity to
file an amended petition. The Court directed petitioners to set
forth with specificity each error they allege was made by
respondent in the determination of the deficiency and separate
statements of fact upon which petitioners base the assignment of
each error. An amended petition was filed in each docket. The
amended petitions, which are virtually identical in each docket,
do not assert any justiciable claims. Petitioners assert in each
of the amended petitions the issues presented as follows:
1. Where is the missing Internal Revenue Code Section
that caused a tax liability?
2. Where is the Statutory Procedurally Correct Lawful
Assessment?
3. Where is Discovery?
4. Should Respondent be Sanctioned?
Discussion
Rule 34(b)(4) requires that a petition filed in this Court
contain clear and concise assignments of each and every error
that the taxpayer alleges to have been committed by the
Commissioner in the determination of the deficiency and the
additions to tax in dispute. Rule 34(b)(5) further requires that
the petition contain clear and concise lettered statements of the
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Last modified: May 25, 2011