Richards Asset Management Trust, et al. - Page 13




                                       - 13 -                                         
               On February 15, 2002, Richards Management Trust, Mr. Rich-             
          ards, and Richards Charitable Trust filed a joint brief in these            
          cases.  That brief sets forth statements, contentions, and                  
          arguments that the Court finds to be frivolous and/or ground-               
          less.9                                                                      

               8(...continued)                                                        
                    taxpayer to pay to the United States a penalty not                
                    in excess of $25,000.                                             
               9Petitioners’ joint brief in these cases states in pertinent           
          part:                                                                       
               This is a proceeding to determine if the Internal                      
               Revenue Service can ignore the strict limitations                      
               imposed on it by Congress, via the Code of Federal                     
               Regulations, and its’ [sic] own required administrative                
               procedures to extort assets from unsuspecting inhabit-                 
               ants of one of the fifty (50) states of the United                     
               States of America, to wit:  Everett D. Richards, et al.                
                  *       *       *       *       *       *       *                   
               U.S.C. Title 26 Section 7602 is the I.R.S.’s authority                 
               to examine books and records regarding “internal reve-                 
               nue tax”--not income tax.  This is corroborated by the                 
               fact that the implementing regulation for Section 7602                 
               is located in C.F.R. Title 27, parts 70, 170 and 296.                  
                  *       *       *       *       *       *       *                   
               In accordance with C.F.R. 1.861-8(f) petitioners, et                   
               al, do not receive any “income” or receipts from a                     
               “taxable source”.                                                      
                  *       *       *       *       *       *       *                   
               Petitioners, et al, have never been legally assessed                   
               any tax as required by U.S.C. Title 26 Section 6203 and                
               C.F.R. regulation 301.6203-1 and corroborated in Bull                  
               v. U.S., 295 US 247 * * *.                                             
               Petitioners, et al, determinations are based on Supreme                
               Court decisions, Treasury Orders, U.S.C. Title 26                      
                                                             (continued...)           



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