Richard E. Marks - Page 3

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               Petitioner filed a petition with this Court in which he                
          provided the following statement as his disagreement with                   
          respondent’s determinations in the notice of deficiency:                    
               (1) The District Director issued a Statutory Notice of                 
               Deficiency claiming petitioner had a tax liability without             
               there being a statutorily procedural correct lawful tax                
               assessment.  (2) Attached to the Notice of Deficiency, IRS             
               Form 4549A, income tax examination changes, line 11 states,            
               “Total Corrected Tax Liability.”  Respondent has failed to             
               provide the petitioners with the internal revenue code                 
               section or regulation that was used to calculate this total            
               corrected tax liability.  (3) The respondent has failed to             
               provide the petitioners with certified assessment                      
               information as per Internal Revenue Regulation 301.6203-1.             
               (4) Respondent has failed to identify the individual who               
               will certify to the tax adjustments the determination was              
               based on.  Therefore, the deficiency is unenforceable as the           
               determination was based on unfounded evidence.  (5) There              
               can be no meaningful administrative hearing until respondent           
               provides petitioner with the above requested information,              
               and until that time, petitioner will disagree with all of              
               the adjustments.                                                       
          The language of the petition is very similar to the language of             
          the petitions in other cases before this Court in which                     
          petitioner was involved.  Petitioner appeared before the Court in           
          his capacity as officer of the corporate trustee of six trusts in           
          six separate docketed cases.  In our opinion in those cases, Funk           
          v. Commissioner, T.C. Memo. 2000-169, we found that the petitions           
          in those cases failed to comply with Rule 34(b)(4) and (5).  Rule           
          34(b)(4) requires that the petition set forth “Clear and concise            
          assignments of each and every error which the petitioner alleges            
          to have been committed by the Commissioner in the determination             
          of the deficiency or liability.”  Rule 34(b)(5) requires that the           

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