The Adorno Asset Management Trust - Page 13

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               10/17/02                 /s/                                           
               Date:                    Edwin Adorno, Trustee                         
                                        Adorno Business Company                       
          The affidavit does not list the name of a “trustee” for Adorno              
          Asset nor make any reference to Adorno Asset’s purported trustee.           
               Mr. Adorno also filed a supplemental objection with his                
          response stating that he is the “trustee” of Adorno Asset and               
          attesting to his capacity and authority to act on behalf of                 
          Adorno Asset.  In addition, Mr. Adorno submitted a “motion to               
          vacate claims, motion for summary judgment and complaint under              
          authority of 26 U.S.C. 7433, 7214(a)”, which the Court filed as a           
          Motion to Dismiss, challenging respondent’s authority to assess             
          tax against Adorno Asset and stating that he is the trustee of              
          Adorno Asset.15                                                             
               G.  Hearing on Respondent’s Motion                                     
               This matter was called for hearing at the Court’s trial                
          session in Chicago, Illinois.16  Counsel for respondent appeared            
          at the hearing and offered argument and evidence in support of              
          respondent’s motion to dismiss.  Specifically, respondent                   


               15  The Court denied Mr. Adorno’s motion by order dated Nov.           
          6, 2002.                                                                    
               16  This case was called for hearing with a related case in            
          which Mr. Adorno also filed a petition purportedly on behalf of a           
          so-called trust, which case is also being dismissed on the ground           
          that it was not filed by a proper party.  See The Adorno Bus. Co.           
          v. Commissioner, T.C. Memo. 2003-126.  Mr. Adorno himself also              
          has a case pending before the Court assigned docket No. 9459-02.            





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Last modified: May 25, 2011