- 6 - facts on which the taxpayer bases the assignments of error. See Jarvis v. Commissioner, 78 T.C. 646, 658 (1982). The petitions and amended petitions filed in these cases do not satisfy the requirements of Rule 34(b)(4) and (5). There is neither assignment of error nor allegation of fact in support of any justiciable claim. Rather, there is nothing but frivolous rhetoric and legalistic gibberish, as demonstrated by the summary of the petitions provided above. Under the circumstances, we see no need to catalog petitioners' arguments and painstakingly address them. As the Court of Appeals for the Fifth Circuit has remarked: "We perceive no need to refute these arguments with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit." Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984); see also Hansen v. Commissioner, 820 F.2d 1464 (9th Cir. 1987); Grimes v. Commissioner, 806 F.2d 1451 (9th Cir. 1986). In docket No. 18510-99, petitioners filed a motion to dismiss for lack of jurisdiction, a motion to compel discovery, and an application for order to take depositions. We denied these motions. Petitioners’ primary argument was that respondent failed to explain the basis for the determination and also that there is no lawful, proper assessment. In docket Nos. 1366-00 through 1371-00, petitioners also filed motions to dismiss for lack of subject matter jurisdiction. The assertions in thosePage: Previous 1 2 3 4 5 6 7 8 9 Next
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