- 10 -
motions, all of the petitioners filed similar documents,
captioned “Petitioners’ Objections to Respondent’s Motion for
Judgment on the Pleadings and Supporting Memorandum” (sometimes,
petitioners’ objections). The memorandum portion of each of
petitioners’ objections states that, although, in the petition,
petitioner (petitioners, in the case of Hae-Rong and Lucy B. Ni)
did state that there were no issues of fact in dispute, such is
no longer the case. Each such memorandum portion claims:
There is no evidence to suggest that there is a bona
fide political relationship between the petitioners and
the “UNITED STATES” and the “STATE OF CALIFORNIA.”
There is no evidence that the petitioners are subject
to the written will of individuals called
“CONGRESSMEN." * * *
Each of petitioners’ objections includes an affidavit of
Ms. Sluyter wherein, among other things, she claims, without
further detail: “There is a factual dispute as to the
Petitioners relationship to the United States and the State of
California.” Ms. Sluyter signed the petitioners’ responses.
Court’s Order Dated April 24, 2000
By order dated April 24, 2000 (the April 24 order), the
Court (1) calendared the motions for judgment on the pleadings
for hearing at the trial session and (2) ordered that, at the
trial session (A) petitioners show cause why the Court should not
impose a penalty pursuant to section 6673(a)(1) (which provides
for a penalty if, among other things, a proceeding is instituted
or maintained primarily for delay or the taxpayer’s position is
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011