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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 set
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Last modified: May 25, 2011