Richards Asset Mgmt. Trust, et al. - Page 19




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          Bentivegna) who identified himself in each such response as                 
          “Trustee”.  Each such response asserted that “Petitioner does not           
          believe that this Court has jurisdiction.”  In support of that              
          position, Richards Management Trust’s response to the December 3,           
          2001 Show Cause Order and Richards Charitable Trust’s response to           
          the December 3, 2001 Show Cause Order set forth statements and              
          contentions that the Court found to be frivolous and/or ground-             
          less.6                                                                      


               6Each such response to the December 3, 2001 Show Cause Order           
          stated in pertinent part:                                                   
               1.   Petitioner petitioned this Court after having                     
                    received false and misleading information from the                
                    respondent and attorneys David Wise and his asso-                 
                    ciate Carol Jackson.  The respondent has failed to                
                    properly assess any taxes in accordance with their                
                    required administrative procedures, and yet ad-                   
                    vised the petitioner that the only method of dis-                 
                    agreeing with the purported tax liability was to                  
                    petition this Court.                                              
               2.   This Courts’ [sic] order states “. . . petitioner                 
                    purports to be a trust . . .”  Petitioner is a                    
                    trust, and the respondent has never been able to                  
                    prove otherwise.  Nor does the respondent have the                
                    right or ability to set aside a contract.                         
                  *       *       *       *       *       *       *                   
               4.   Petitioner does not want this false tax claim to                  
                    be litigated in court, and has petitioned this                    
                    Court to have this case removed from the docket as                
                    having been petitioned in error due to the errone-                
                    ous instructions given by the respondent.                         
               WHEREFORE it is prayed that:                                           
               1.   This Court dismiss this case at petitioner’s re-                  
                                                             (continued...)           





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