Manuel G. Lopez - Page 7




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                  On August 28, 2000, petitioner moved for leave to amend the                          
            petition.  Petitioner’s motion was granted, and the amended                                
            petition accompanying the motion was filed on August 30, 2000.                             
            The amended petition alleges that respondent failed to consider                            
            the tax returns for the taxable years 1994, 1995, and 1996 that                            
            petitioner had submitted to respondent on July 7, 2000.  Attached                          
            to the amended petition are copies of the tax returns for 1994,                            
            1995, and 1996.  The tax returns are computed using the married                            
            filing jointly filing status and are signed by petitioner and his                          
            wife, Rafaela B. Lopez.  The attached 1994 tax return is                                   
            purportedly an amended return and is signed with dates of June 18                          
            and 20, 1996.                                                                              
                  On September 11, 2000, respondent filed a motion to show                             
            cause why proposed facts in evidence should not be accepted as                             
            established.  The motion sets forth allegations regarding                                  
            petitioner’s lack of cooperation with respondent.  The Court                               
            entered an order to show cause on September 15, 2000.  Due to a                            
            response from petitioner’s counsel alleging ongoing negotiations                           
            and the subsequently filed supplemental stipulation of facts, the                          
            order to show cause was discharged on October 12, 2000.                                    
                  Respondent filed an answer to petitioner’s amended petition                          
            on September 19, 2000.  Respondent’s answer to amended petition                            
            asserted increased deficiencies and additions to tax pursuant to                           
            section 6214(a) as follows:                                                                






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