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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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