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tax liability.1 Respondent currently moves the Court for summary
judgment and to impose a penalty under section 6673. Respondent
attached to his motion the declaration of his counsel, Wendy S.
Harris, and 11 exhibits.
Petitioner filed with the Court a response (response) to
respondent’s motion and attached to the response one exhibit.
The response states that petitioner disputes as a factual matter
that he has a deficiency for 1999 and references the attached
exhibit, a 1999 Form 1040, U.S. Individual Income Tax Return,
that petitioner recently prepared to support his claim in the
response that he overpaid his 1999 Federal income tax.
Respondent previously issued to petitioner a notice of deficiency
for 1999. Petitioner did not petition this Court with respect to
that notice, and he does not in the response dispute that he had
an opportunity to challenge his 1999 liability before commencing
the section 6330 proceeding as to that year. The response also
sets forth numerous assertions concerning our Federal income tax
system. Those assertions include petitioner’s claim that he is
not a taxpayer and does not have any income that may be taxed;
that respondent is not authorized to determine a deficiency; that
petitioner is not a taxpayer and, thus, does not have a
“deficiency” within the meaning of that word; that respondent is
1 Section references are to the applicable versions of the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
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Last modified: May 25, 2011