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petitioner’s response to respondent’s motion a copy of peti-
tioner’s memorandum in opposition that respondent attached as an
exhibit to respondent’s supplement to respondent’s motion.
Discussion
Rule 34(b) provides in pertinent part that a petition with
respect to a notice of deficiency is to contain:
(4) Clear and concise assignments of each and
every error which the petitioner alleges to have been
committed by the Commissioner in the determination of
the deficiency * * *. * * * Any issue not raised in the
assignments of error shall be deemed to be conceded.
* * *
(5) Clear and concise lettered statements of the
facts on which the petitioner bases the assignments of
error * * *.
The petition that petitioner filed on September 16, 2005,
and the amended petition that petitioner filed on January 6,
2006, do not contain (1) a clear and concise statement of the
errors allegedly committed by respondent in determining the
deficiency with respect to petitioner’s taxable year 2002 and
(2) a clear and concise statement of the facts that form the
basis of petitioner’s assignments of alleged error. We conclude
that both the petition and the amended petition that petitioner
filed do not comply with the Tax Court Rules of Practice and
Procedure as to the form and content of a petition.
Moreover, we have found that the petition and the amended
petition that petitioner filed contain statements, contentions,
and arguments that are frivolous and groundless. “A petition
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