US TAX COURT

WASHINGTON, DC

 

 

Guido A. Improta                                         )

                             )

Petitioner,                      )

)            Docket No.  25833-06L

V.                                                      )        relates to the Motions Session

)                  on May 16, 2007

Commissioner of Internal Revenue,               )

)

Respondent.           )

 

WRITTEN STATEMENT IN LIEU OF ATTENDANCE AT ABOVE HEARING

 

Petitioner submits this written statement, pursuant to Rule 50 (c) of the Tax Court due to his

inability to attend above said hearing.

 

1. In previous motions and copies of letters sent to the Tax Court as listed here and

 

incorporated by reference;

 

A. Petition for Re-determination of the Notice of Determination

 

     dated December 9, 2006

 

B. Supplement to Re-determination of the Notice of Determination

 

     dated January 9, 2007

 

C. Copy of Letter of Confirmation dated March 7, 2007

 

D. Reply to Answer dated March 14, 2007

 

E. Objection to Motion to Remand dated March 21, 2007

 

F. Motion for Reconsideration of Order dated March 23, 2007

 

G. Addendum to Motion for Reconsideration of Order dated March 28, 2007 

 

Petitioner has continually shown that District Counsel has filed frivolous, incorrect, inaccurate and

 

groundless pleadings before this Tax Court.

 

2. Petitioner offered to settle this case with District Counsel for only 20% of what the law

 

allows, $5000, and a remand to the Office of Appeals. District Counsel refused to pay Petitioner

 

for his erroneous, frivolous, inaccurate and incorrect pleadings before this Court.

 

3. Petitioner continues to suffer severe emotional stress, physical pain and mental anguish

 

as a result of District Counsel’s extremely poor and inaccurate conduct in this case.  

 

4. The Tax Court has sanctioned over one hundred thousand pro se litigants for

 

continuing poor and frivolous pleadings before the Court but not once has it sanctioned a District

 

Counsel for doing the same.

 

5. The Tax Court needs to be impartial and should move to grant Petitioner $25,000 in

 

sanctions plus out-of-pocket expenses of $2,100 in lieu of attorneys fees due to the poor,

 

erroneous, inaccurate, untrue and harassing pleadings of District Counsel.

 

 

CERTIFICATE OF SERVICE: I do hereby certify on this date that a copy this pleading was sent properly to opposing counsel.

_________________________ Date:   May 7, 2007

Guido A. Improta

26368 Lexington Drive

Bonita Springs, FL 34135

 

239-498-1701