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C. Shirleys as it is for the J. Shirleys, and we shall not repeat
it. We sustain the penalty on the same grounds, modified only to
take account of the deficiency that we have determined.
2. Section 6673(a)(1)
We likewise impose a penalty under section 6673(a)(1)
against the C. Shirleys for substantially the same reasons that
motivated us with respect to the J. Shirleys. The C. Shirleys
did not fail to reply to admissions, since they were not served
with any. Their petition, however, is replete with frivolous and
groundless claims. For example:
The Notice of Deficiency is required by the Internal
Revenue Code to be signed by a duly appointed
assessment officer. There is nothing to indicate that
the person signing (rubber-stamped signature) the
Notice of Deficiency or the Form 4549-A attachment
(unsigned) are [sic] duly authorized to perform that
function. Internal Revenue Code �6201 and 26 USC
�6065, clearly defines that a duly authorized signature
be present on these forms. Petitioners have no means
to confirm that the signatures are that of a duly
authorized person.
Petitioners, on information and belief, alleges [sic]
that the sole purpose of the respondent’s Notice of
Deficiency is for the obvious purpose of ensnaring the
Petitioners into a fraudulently obtained Federal Tax
Court jurisdiction. Petitioners’ position is that the
respondent knew or should have known that he has
violated the petitioners’ right of due process in
forcing this filing.
On the provision that the Petitioners are properly
documented in their “Individual Master File” (IMF),
this [sic] petitioners’ source of revenue is from
within the several states and does not conform to any
federally regulated “taxable objects”. The petitioners
do not fall under the definition found in the IRC
3121(h), since the petitioners do not reside in the
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