Anonymous Taxpayer,                            )
(Michael Patriot)                              )   Docket No. 06-ALJ-17-0000-xx
Petitioner                                     )
Vs.                                            )
South Carolina Department                      )   OPPOSITION TO MOTION TO COMPEL
Of Revenue                                     )   PRODUCTION OF DOCUMENTS 
Respondent.                                    )

Petitioner hereby files his opposition to DORs Notice and Motion to Compel Response to Requests for Production of Documents dated Dec 20, 2006 for tax year 1999.

  1. Counsel for DOR is a learned lawyer very familiar with the Tax Administrative Law. Taxpayer is a working man with a limited education. DOR Lawyer is taking advantage of taxpayer who has limited resources.

Taxpayer filed his responses to Discovery on time and did the best he could. Taxpayer requests a hearing on respondent’s motion. Further Taxpayer requests an out of court settlement and waiver of penalties.

  1. Taxpayer has faithfully submitted the documentation that existed and has no other documentation to submit or the documents are already in possession of the department.

Employers do in fact submit individual W-2 information concerning their employees to the department. If DOR does not keep adequate records, this is their problem. As well known, Taxpayers are heavily punished for not having copies of their financial records. What is good for the goose is also good for the gander.

  1. Counsel for DOR sent an insulting and harassing letter to Taxpayer on Dec 7, 2006 which was attachment VI to their Motion to Compel. Even though the US Congress has outlawed the use of the term “tax protestor,” Mr. Urban continues to use this incorrect and unjust term.

He should be required to recall that letter and be admonished by this Court for using said term. Or he should be required to produce proof and documentation that petitioner is one to be so classified. Nothing in this record contains any stalling or delaying tactics by a pro se litigant who is unfamiliar with the procedures of this Court.

  1. Taxpayer is unable to make telephone calls to Mr. Urban as taxpayer, a pro se litigant, does not have the expertise to talk to experienced and tough Counsel for DOR. Further the Tax Collectors in this country have a terrible reputation for intimidation and untruthful statement.
  1. Therefore Taxpayer requests that DOR accept his Response to POD even though his language and procedure may not be perfect.

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

___________________________________              Date: January 12, 2006

Michael Patriot
1776 Patriot Way
Spartanburg, USA