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had not had adequate time to address the motion before trial. We
invited petitioner to offer during the trial any evidence that
supported his claim that we lacked jurisdiction and to argue the
merits of the claim on brief. Petitioner rested his case without
testifying, calling any witnesses, or offering any evidence at
all.
Respondent called no witnesses but did offer into evidence
certified transcripts of account of the Forms 1040, U.S.
Individual Income Tax Return for petitioner for his tax years
ending December 31, 2000 and 2001 (the transcripts of account).
The Court overruled petitioner’s relevancy objections and
instructed the parties to address on brief petitioner’s argument
that the transcripts of account had not been shown to be
authentic because, although they were accompanied by certificates
under seal and signed (the certificates), the certificates did
not bear any date.
Petitioner filed a petition and an amended petition. At the
time he filed the amended petition, petitioner’s mailing address
was in Spring, Texas. Petitioner, although proceeding pro se, is
an attorney admitted to practice before this court.
Attached to the petition is a copy of what petitioner
describes in the petition as an “alleged” notice issued by the
Internal Revenue Service (IRS) for 2001. The attachment is a
two-page letter dated November 29, 2004 (the November 29 letter),
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