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those for 1989. United States v. Summers, No. 2002-CV-1812 (E.D.
Pa.). During June 2002, Mr. Summers filed an answer and cross-
complaint challenging the tax assessments and the amounts of his
tax liabilities, including those for 1989.2 On August 9, 2002,
respondent filed a motion for summary judgment. During September
2002, Mr. Summers filed a reply to respondent’s motion and a
motion to dismiss for lack of subject matter jurisdiction.
On October 7, 2002, respondent filed a motion to dismiss
Mr. Summers’s counterclaims.
On March 27, 2003, the District Court issued a memorandum
opinion and entered an order granting respondent’s motions for
summary judgment and to dismiss Mr. Summers’s counterclaims and
gave respondent 30 days to present a full and final accounting of
Mr. Summers’s tax liabilities, including 1989. See United States
v. Summers, 254 F. Supp. 2d 589 (E.D. Pa. 2003).
On April 22, 2003, Mr. Summers filed a memorandum and
declaration in response to the District Court’s March 27, 2003,
order. On May 30, 2003, Mr. Summers filed a memorandum in
response in which he claimed that respondent had received, or
should have received, $246,991.72 from Commonwealth and $26,000
2Mr. Summers’s answer and cross-complaint contained, inter
alia, several frivolous tax protester type arguments including:
He is not a taxpayer within the meaning of the Internal Revenue
Code; there is no “1040 tax” listed in the index of the Internal
Revenue Code; and that the United States and its agents
fraudulently misled him to believe that compliance with the
Internal Revenue Code was mandatory.
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