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CONCLUSIONS AT LAW TAX COURT JUDGE DEMANDED.” Petitioner
attached to the petition: (1) The first page of the notice of
deficiency for 2002; (2) the decision letter for 2001; (3) the
notice of determination regarding the proposed levy for income
taxes for 1999 and 2000; and (4) the notice of determination
regarding notice of Federal tax lien for the section 6702 penalty
for 1999 and 2000.
On October 29, 2004, respondent filed a motion to dismiss
for failure to state a claim upon which relief could be granted.
On November 15, 2004, petitioner filed an objection to
respondent’s motion to dismiss.
On February 7, 2005, petitioner filed a motion to enforce
Rule 36.2 This motion contained frivolous and groundless
arguments. The Court denied this motion.
Petitioner attempted to file several other documents with
the Court that the Office of the Clerk of the Court returned to
petitioner as unfilable. The returned documents included a
“motion to set aside defaults” and a “verified motion to enforce
default against IRS by summary judgement”. These documents
contained frivolous and groundless arguments.
2 Rule 36(a) provides, in pertinent part, that “The
Commissioner shall have 60 days from the date of service of the
petition within which to file an answer, or 45 days from that
date within which to move with respect to the petition.”
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Last modified: May 25, 2011