MatrixInfoSys Trust - Page 4




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               On August 19, 1999, the trust’s case was calendared for the            
          Court’s trial session beginning January 24, 2000, in San                    
          Francisco, California.  On November 5, 1999, respondent filed a             
          motion for continuance of trial with regard to the trust’s case             
          on the ground that respondent would seek to have the trust’s case           
          consolidated with petitioner’s individual case (described below);           
          we granted respondent’s motion on January 10, 2000.  On May 16,             
          2000, the trust’s case was rescheduled for trial to the San                 
          Francisco, California, trial session beginning October 16, 2000.            
               B.   Petitioner’s Individual Tax Case                                  
               On October 12, 1999, petitioner filed a petition for                   
          redetermination with regard to his 1994, 1995, 1996, and 1997 tax           
          years.  Petitioner asserted that he had not received the income             
          determined by respondent, and therefore he was not liable for the           
          deficiencies and additions to tax described in the notice of                
          deficiency.2  Petitioner requested that the matter be transferred           
          to an IRS Appeals Office because the notice of deficiency was               
          allegedly incomplete and erroneous.  In support of his request,             
          petitioner alleged that he had been denied “due process of law”             
          and that he had a claim under the “Taxpayer Bill of Rights”                 
          against the IRS.  Finally, petitioner also alleged a laundry list           
          of defenses:                                                                


               2  In actuality, respondent determined the deficiencies and            
          the additions to tax relating to petitioner’s income taxes for              
          the years in issue in two separate notices.                                 




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