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In his petition, petitioner contended without elaboration
that respondent had erred in determining that he had gross and
taxable income; that he was entitled to “personal exemptions,
deductions and possibly business expenses”; and that the notice
of deficiency was invalid because “the Internal Revenue Service
failed to execute an involuntary return as required by the IR
Code.”
By Order dated November 28, 2005, the Court directed
petitioner by December 28, 2005, to file a response to
respondent’s motion to compel production of documents, in which
respondent requested documentary evidence to substantiate
petitioner’s claimed entitlement to deductions or exemptions.
Petitioner having filed no response, on January 6, 2006, the
Court granted respondent’s motion to compel production of
documents. On February 13, 2006, petitioner untimely filed his
response to respondent’s motion to compel production of
documents. Petitioner’s response was not fairly directed to the
substance of respondent’s request for production of documents but
instead asserted that by failing to produce Form 23C, Assessment
Certificate--Summary Record of Assessments (Form 23C), respondent
was proceeding “illegally and prematurely to collection
activities”.
On February 3, 2006, this Court entered summary judgment for
respondent in the case at docket No. 22706-04L, a collection case
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