Loran J. Forbes - Page 2

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          can be granted and to impose a penalty under I.R.C. section 6673            
          (motion to dismiss).1                                                       
               On June 13, 2005, petitioner filed a petition with the                 
          Court.  By order dated June 21, 2005, the Court directed                    
          petitioner to file a proper amended petition on or before August            
          5, 2005.  Petitioner filed the amended petition on August 4,                
          2005, based upon notices of determination concerning collection             
          action(s) under section 6320 and/or 6330.  In the amended                   
          petition, petitioner seeks redetermination of the deficiency and            
          review of lien and levy actions for the 1997, 2000, and 2001 tax            
          years.  Petitioner also alleges that “Notice of administrative              
          judgment by estoppel with sixty three (63) exhibits is                      
          evidenced”.                                                                 
               On September 6, 2005, respondent’s motion to dismiss was               
          filed.  In his motion, respondent asserts that petitioner makes             
          no factual claims of error and asserts only law and legal                   
          conclusions in the petition.  Respondent further argues that                
          petitioner’s claims are “nonsensical on their face.”  On                    
          September 12, 2005, petitioner filed his objection to                       
          respondent’s motion to dismiss.  On November 30, 2005,                      
          petitioner’s supplemental objection to respondent’s motion to               
          dismiss was filed.                                                          


               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      




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