Said Jumaa - Page 10




                                       - 10 -                                         
               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.                                                                       







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next 

Last modified: November 10, 2007