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X THE “CLEAN HANDS” DOCTRINE (UNCLEAN HANDS OF
RESPONDENT)
X ILLEGALITY
X FAILURE OF JURISDICTION OVER PETITIONER
DISCHARGE IN BANKRUPTCY
OTHER________________________________________
A petition filed under section 6330(d)(1)(A) must contain
“Clear and concise assignments of each and every error”. Rule
331(b)(4). Further, “clear and concise lettered statements of
the facts on which the petitioner bases each assignment of error”
must be contained in the petition. Rule 331(b)(5). If any issue
is not raised in the petition, it “shall be deemed to be
conceded.” Rule 331(b)(4). Further, the prayer for relief shall
be set forth in the petition. Rule 331(b)(6). Petitioner was
not represented by counsel at the time he filed his petition.
Petitioner, nevertheless, has an obligation to comply with the
Rules of this Court. The broad and general issues that
petitioner raised do not even come close to complying with those
Rules.5 In any event, the issues that petitioner presented
throughout the proceedings in this case do not raise a genuine
issue of material fact.
At the Appeals hearing, petitioner attempted to challenge
the underlying tax liability. Specifically, petitioner argued
5In his petition, petitioner presents a laundry list of
defenses to his tax liability and to the proposed collection
activity. Petitioner alleged no facts in support of those
defenses in his petition, in the Appeals hearing, or in documents
submitted to IRS Appeals or this Court. Our review of the record
shows that the defenses pleaded by petitioner have no merit.
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Last modified: May 25, 2011