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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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Last modified: May 25, 2011