- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011