Ryan David Funk - Page 4

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          resided in Rocklin, California, at the time the petition was                
          filed.                                                                      
               Respondent filed a motion to dismiss for failure to state a            
          claim upon which relief can be granted.  The Court subsequently             
          ordered petitioner to file a proper amended petition setting                
          forth with specificity each error allegedly made by respondent in           
          the determination of the deficiency and the addition to tax in              
          dispute and separate statements of every fact upon which the                
          assignments of error are based.  In response to the Court’s                 
          Order, petitioner filed an amended petition, an objection to                
          respondent’s motion, and a motion to dismiss for lack of subject            
          matter jurisdiction.  In each of the above-referenced documents,            
          petitioner continued to assert the frivolous arguments set forth            
          in the petition.4                                                           
               Respondent’s motion to dismiss was called for hearing at the           
          Court’s motions session held in Washington, D.C.  Counsel for               
          respondent appeared at the hearing and presented argument in                
          support of respondent’s motion to dismiss.  No appearance was               
          entered by or on behalf of petitioner at the hearing; however,              
          petitioner filed with the Court a written statement pursuant to             
          Rule 50(c).                                                                 




               4We summarily denied petitioner’s motion to dismiss by Order           
          dated June 16, 2004.                                                        





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