- 2 - in petitioner’s 2002 Federal income tax and additions to tax under sections 6651(a)(1) and 6654(a) in the respective amounts of $1,006.01 and $115.92. The taxable income upon which the notice of deficiency is predicated was derived from third-party reporting forms. Petitioner filed a timely petition in which he sets out a farrago of nonsense as to why the notice of deficiency is invalid and he does not owe the tax determined. At the time the petition was filed petitioner resided in West Allis, Wisconsin. Respondent’s motion to dismiss was filed on October 7, 2004. On October 12, 2004, the Court ordered that petitioner file an amended petition “in which he sets forth with specificity each error he alleges was made in the determination of the deficiency and separate statements of every fact upon which petitioner bases the assignment of each error.” See Rule 34. The Court also set respondent’s motion for hearing at the Trial Session of December 13, 2004, in Milwaukee, Wisconsin. Rather than complying with the Court’s Order of October 12, 2004, petitioner filed a document that contained the same nonsense. When this case was called from the calendar petitioner was told that he had not complied with the Court’s Order and that his arguments were frivolous and without merit. See, e.g., Coleman v. Commissioner, 791 F.2d 68 (7th Cir. 1986); Rowlee v.Page: Previous 1 2 3 Next
Last modified: May 25, 2011