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“that the requirements of any applicable law or administrative
procedure have been met”, for example, a copy of the statutory
notice and demand for payment; (2) a copy of Form 23C, Summary
Record of Assessment, and the “pertinent parts of the assessment
etc.etc.etc.”; (3) delegation of authority from the Secretary to
the person (other than the Secretary) who signed the verification
required under section 6330(c)(1); and (4) proof that notices of
deficiency were sent to petitioner.
On December 14, 2001, petitioner filed a motion to dismiss
for lack of jurisdiction. A hearing on the motion was held on
March 11, 2002, with Judge Arthur Nims presiding. On January 8,
2003, this Court filed Green v. Commissioner, T.C. Memo. 2003-7,
holding that the Court had jurisdiction.
Respondent filed an answer to the petition on January 23,
2003. On May 7, 2003, respondent filed a motion for summary
judgment for all legal issues in controversy. On May 22, 2003,
Jerry Arthur Jewett (Mr. Jewett) executed Form 2848, Power of
Attorney and Declaration of Representative, on behalf of
petitioner.
On June 11, 2003, Mr. Jewett filed his entry of appearance
and, on June 29, 2003, filed a reply to respondent’s motion for
summary judgment, which contained tax-protester boilerplate
arguments, including:
because petitioner assessed himself as owing “$0.00" in
subtitle A taxes for 1996, pursuant to �6211, and because
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