The Nis Family Trust - Page 10




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            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                            





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