- 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 isPage: 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