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determined an increase in petitioner’s income tax of $2,983. The
increased income tax amount of $2,983 was also reflected on the
Waiver Statement and the Notice of Deficiency Statement.
Petitioner filed a petition with the Court, attaching an 8-
page statement that included a “detailed explanation of
disagreement” with respondent’s determinations and a request for
a finding that the notice of deficiency is invalid on its face.
Respondent filed a Motion To Strike Portions Of The
Petition, requesting the Court to strike various sentences in
paragraphs 1 through 7 of petitioner’s statement attached to the
petition. Respondent asserts that the language sought to be
stricken in the petition is not proper, does not comply with the
Rules, and makes frivolous, vague, and immaterial allegations and
assertions with no factual basis.
Petitioner’s Opposition To Respondent’s Motion To Strike
Portions Of The Petition was filed claiming respondent’s motion
has no merit. Petitioner claims that each paragraph in the
petition contains a clear and concise assignment of error
committed by respondent. Further, petitioner contends that
respondent misinterprets Rule 34(b) to require that “each and
every sentence of the petition be enumerated” and asserts that
respondent moves to strike portions of the petition solely on
that misunderstanding.
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Last modified: May 25, 2011