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Inc., not contained in the notice of deficiency, respondent also
asserted that the total additions to tax pursuant to sections
6651(a) and 6654(a) are $3,001.50 and $642.33, respectively.
That same day, petitioner filed a motion to shift the burden
of proof to respondent pursuant to section 7491 and a motion for
interlocutory review of the March 17 order.
On April 9, 2004, petitioner filed a notice of refusal to
stipulate.
On April 13, 2004, the Court denied petitioner’s motion for
interlocutory review. In order to give petitioner time to file a
reply to the answer, the Court also ordered this case stricken
from the Court’s Dallas, Texas, session beginning April 26, 2004,
and continued it generally.
On April 22, 2004, petitioner filed a motion for stay, an
objection regarding the docket sheet, a second motion for
judgment on the pleadings, and a motion for interlocutory appeal.
In the objection, petitioner objected to the capitalization
of certain letters of his name and to the address listing
petitioner as a “resident” of a State “via the identifier of
‘TX.’” Petitioner claimed he was not a resident of that State.
In his objection regarding the docket sheet, beneath his
signature, petitioner listed his address as 1908 Vassar Drive,
Richardson, Texas 75081. This is the same address that
petitioner had listed in his imperfect petition.
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