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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 those
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