The Nis Family Trust - Page 11




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            frivolous or groundless), and (B) Ms. Sluyter show cause why she                           
            should not be required to pay costs pursuant to section                                    
            6673(a)(2) (which provides that costs may be imposed on counsel                            
            who has multiplied the proceedings in any case unreasonably and                            
            vexatiously).                                                                              
            Motions to Compel                                                                          
                  On April 24, 2000, by one consolidated motion, made in each                          
            of these cases, respondent moved to compel (1) production of                               
            documents and (2) answers to interrogatories (the motions to                               
            compel).  In support of the motions to compel, respondent set                              
            forth a history of unfulfilled requests for both informal and                              
            formal discovery.  In support of the motion to compel answers to                           
            interrogatories, respondent set forth the following description                            
            of an April 4, 2000, meeting among respondent’s counsel,                                   
            Ms. Sluyter, and an individual named Mark MacDonald:                                       
                  On April 4, 2000, respondent’s counsel met with                                      
                  attorney Sluyter and Mark MacDonald, a representative                                
                  of petitioners, regarding respondent’s informal and                                  
                  formal discovery requests and about the legal theories                               
                  presented in these consolidated cases.  Attorney                                     
                  Sluyter and Mr. MacDonald set forth a variety of                                     
                  arguments on petitioners’ behalf, including:  (1) that                               
                  what the United States government calls the “federal                                 
                  law” is not applicable to petitioners Frank [Hae-Rong]                               
                  and Lucy Ni, (2) that Frank [Hae-Rong] and Lucy Ni have                              
                  no affiliation to the “so-called United States,”                                     
                  (3) that the Internal Revenue Service has no                                         
                  jurisdiction to audit the income tax returns of Frank                                
                  [Hae-Rong] and Lucy Ni, and (4) that Frank [Hae-Rong]                                
                  and Lucy Ni can have no tax liability because no                                     
                  consideration exists between the Ni’s and the United                                 
                  States government.  Further, Attorney Sluyter stated                                 
                  that petitioners would not be providing respondent’s                                 





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Last modified: May 25, 2011