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IN THE UNITED STATES DISTRICT COURT
Ward Dean, M.D. CASE NO: 3:03cv65/LAC/MCR
COMES NOW, Dr. Ward Dean, Plaintiff in the above styled action, to propound Plaintiff’s Second set of interrogatories pursuant to Federal Rules of Civil Procedure and Rules 26.1 (I) and 26.2 of the Rules of the US District Court for the Northern District of Florida. 1. State what class of tax is being investigated in the instant case. 2. What taxing and liability statutes, along with implementing regulations, made me a person liable for keeping books and records and filing returns for that statute? 3. What internal revenue district, established in compliance with requirements of 26 U.S.C. § 7621 and Executive Order #10289, is the situs of the taxable articles, activities and/or transactions from which the alleged taxable income you were investigating derived? 4. What delegated authority, whether statutory or otherwise, does Agent Burgess have for administering the class or classes of tax named in response to interrogatory #1 above? 5. What “officer, employee, or agency of the Treasury Department [or] other officer of the United States” is the delegate of the Secretary for purposes of collection of the tax agent Burgess was investigating as stated in response to #1 above in States of the Union? (26 U.S.C. § 7701(a)(1)(A)) 6. What order, agreement, contract or other such device does agent Burgess have that authorizes investigation activity on behalf of the “delegate” of the Secretary, as defined at 26 U.S.C. § 7701(a)(12)(A), in States of the Union? See §§ 1001(b)(2) of P.L. 105-206. 7. What is the geographical limitation (venue) of agent Burgess’ statutorily authorized delegated authority for investigating the class or classes of tax at issue? (See 4 U.S.C. § 72; see also, 26 U.S.C. § 7701(a)(12)(B)) 8. For calendar years 1997 through 2001, have proper notices and demands for payment been issued to me subsequent to execution of assessment certificates in compliance with 26 U.S.C. § 6303 and 26 CFR § 301.6303-1? Respectfully submitted, _______________________
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