Regina S. Davis - Page 5




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          Service is a function of the Puerto Rican Bureau of Alcohol,                
          Tobacco and Firearms”; (4) “the Secretary of Health and Human               
          Services is the only one who can determine * * * wages”; (5) “the           
          [Form] 1040 * * * was classified as [a] Virgin Island Return” and           
          petitioner had no connection with the Virgin Islands; (6) “it’s a           
          felony to disclose the social security [number] to the Internal             
          Revenue Service prior to service of a 6001 notice”; and (7) the             
          Internal Revenue Service is not “an agency of the United                    
          States”.3                                                                   
               Initially, we note that the petition for review of                     
          respondent’s determination to proceed with levying petitioner’s             
          property does not satisfy the requirements of our Rules.  Rule              
          331(b) requires that the petition contain clear and concise                 
          assignments of each and every error in respondent’s determination           
          and clear and concise statements of the facts on which petitioner           
          bases each assignment of such error.  A general statement that              
          petitioner was denied “due process” is insufficient.                        


          3   In response to respondent’s motion for summary judgment,                
          petitioner filed a “Motion to Strike for Lack of Personam                   
          Jurisdiction” in which she states that “the United States Tax               
          Court * * * lacks jurisdiction over states of the United States             
          of America and is limited to the states of the United States,               
          which includes the District of Columbia, Puerto Rico, Virgin                
          Islands, Guam, American Samoa, other unnamed possessions and                
          insular possessions of the Federal government.”  Petitioner’s               
          conclusion is that the Tax Court’s jurisdiction is limited to the           
          District of Columbia, Puerto Rico, territories, and insular                 
          possessions and, accordingly, the Court lacks jurisdiction to               
          accept motions filed by the Commissioner.                                   





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