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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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