- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011