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protester arguments that demand no respect from the courts.
Petitioners have failed to make any legitimate challenge to the
deficiencies determined by respondent. They have not assigned
any error that could possibly influence us to redetermine the
deficiencies determined by respondent.
C. Conclusion
In the petitions, petitioners have failed to address any of
the adjustments made in the notices of deficiency. We,
therefore, consider petitioners to have conceded those
adjustments. See Rule 34(b)(4). They have made no other
argument of which we take cognizance. We shall grant the motions
for judgment on the pleadings.5
II. Motions For Partial Summary Judgment
A. Introduction
1. Background
The motions for partial summary judgment ask for partial
summary adjudications as to the section 6662(a) penalties. Those
motions were made following respondent’s amendments to the
5 Under various of the theories underlying respondent’s
adjustments with respect to petitioners Hae-Rong and Lucy B. Ni
(e.g., the income of the Trusts is taxed to Hae-Rong and Lucy B.
Ni because the Trusts are shams with no economic substance), the
Trusts would owe no income tax and there could be no deficiency
in tax. Respondent has, nevertheless, with respect to the
Trusts, determined deficiencies in tax. We recognize that
respondent may issue inconsistent notices in order to protect his
interests. We will delay entering decisions in these cases until
the parties have had the opportunity to advise us how we should
deal with any inconsistencies.
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