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Background
On December 2, 2004, respondent issued a notice of
deficiency in which respondent determined a $131,093 deficiency
in petitioners’ 2001 Federal income tax and a $26,218.60
accuracy-related penalty under section 6662. In January 2005,
the Court filed as an imperfect petition a document submitted by
petitioners in which they stated that they were contesting the
amounts set forth in the notice of deficiency.1 A week later,
the Court ordered petitioners to file a proper amended petition
and to pay the filing fee. On February 28, 2005, petitioners
filed an amended petition (first amended petition) in which they
alleged:
We are requesting injunctive relief totaling $50,000. Plus
costs as The United States Tax Court deems appropriate.
Because our 1040 tax form is subject to the 3 year statute
of limitations that binds us and the commissioner. Instead,
IRS issued a 90 day letter without conducting a field audit
at our former place of residence. This arbitrary decision
involves $157,311.60 worth of retaliation and harassment
contrary to The Tax Code or IRS rules. We ask dismissal or
reversal of all determinations on record.
About 2 weeks later, respondent filed a motion pursuant to
Rule 51(a) for a more definite statement as to the nature of
petitioners’ first amended petition, the relief requested
therein, and the reasons for which petitioners believed they were
1 At the time of filing, petitioners resided in Ann Arbor,
Michigan.
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