Timothy Nicholls - Page 15

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          adjustments.  Petitioner was ordered to show cause why the                  
          proposed facts in the stipulation should not be admitted as true,           
          whereupon petitioner made directly contradictory statements under           
          oath.  Petitioner asserted a jurisdictional challenge to the                
          notices of deficiency, premised on the shopworn argument that the           
          notices were void because they were not issued by an authorized             
          individual with either statutory or delegated authority to do so.           
          That argument is without merit, see Nestor v. Commissioner, 118             
          T.C. 162, 165 (2002), and we denied that motion.                            
               Petitioner’s intention to institute and maintain this                  
          proceeding for delay is also indicated by his failure to file a             
          pretrial memorandum, as required by the Court’s pretrial order.             
          Moreover, at the trial, the Court ordered petitioner to file a              
          memorandum in support of his objections to two of respondent’s              
          exhibits, but petitioner failed to do so.                                   
               In sum, petitioner failed to file Federal income tax returns           
          for the years at issue and offered no credible justification for            
          that failure.  He instituted a proceeding in this Court without             
          assigning any specific errors to respondent’s determinations.  He           
          failed to cooperate with respondent in preparing this case for              
          trial, and essentially failed to produce any evidence whatsoever            
          to justify his blanket rejection of respondent’s deficiency                 
          determinations.  We interpret those actions as evidence of his              
          intent to delay this proceeding; he has also advanced frivolous             
          arguments.  He has caused both the Court and respondent to expend           





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