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As directed by the Court, petitioner filed a response to
respondent’s motion. That response stated:
This letter is in response to the motion filed for
summary judgment. I would respectfully ask that this
judgment not be granted to the respondent. As I am
currently in the process of addressing all the concerns
and the requested documents asked by the respondent.
[Reproduced literally.]
Petitioner filed petitioner’s response to respondent’s
motion over six months ago. The Court has given petitioner ample
time to establish his claim that respondent’s motion should not
be granted. He has failed to do so.3
Based upon our examination of the entire record before us,
we conclude that petitioner has failed to show that there are
genuine issues of material fact regarding the questions raised in
respondent’s motion. On that record, we find that petitioner has
failed to show error in the determinations that respondent made
in the notice of deficiency that respondent issued to him for his
taxable year 1998. On the record before us, we find that the
determinations in the notice of determination with respect to
petitioner’s taxable year 1998 should be sustained. On that
3The petition that petitioner filed in this case also is
unhelpful to petitioner’s position. The only issue that
petitioner appears to raise in the petition in this case is the
underlying tax liability for his taxable year 1998. However,
petitioner fails to allege any specific error in the petition
relating to the determinations that respondent made in the notice
of deficiency that respondent issued to him with respect to that
year.
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Last modified: November 10, 2007