- 6 - Within 30 days of the notice of determination, petitioner filed a petition with the Court commencing this levy action. Paragraph 4 of the amended petition sets forth the reasons for petitioner’s belief that he is entitled to relief. It states as follows: 4. Set forth the relief requested and the reasons why you believe you are entitled to such relief. 1) I interpreted the “relief” to mean why I couldn’t pay the $60 Court Cost. 2) I have responded to every letter the IRS has sent with questions and the only response was more intimidating letters until 2002, when I received “Frivolous questions” - “frivoulous [sic] - meaning without serious attention. One of the questions is where is the legislative regulation that requires individuals [sic] taxpayers to file. I can’t locate it. After respondent filed his motion for summary judgment, the Court gave petitioner a period of time in which to respond to respondent’s motion. Petitioner chose to file his own motion for summary judgment in response to respondent’s motion. In that document, petitioner acknowledges that he received the notice of deficiency dated October 13, 1998, issued for taxable year 1996, but he does not address any other facts of the case. Significantly, petitioner’s motion takes issue with none of the facts setPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011