- 4 - rights in law, equity and all other natures of law. 'Without Prejudice' UCC 1-207".3 On June 28, 1995, the Court issued an Order directing petitioner to file a proper amended petition on or before August 28, 1995. On August 30, 1995, petitioner filed an amended petition using a petition form furnished by the Court. Although paragraph 1 of the amended petition states that petitioner disagrees with tax deficiencies for the years 1984 through 1992, the items listed in paragraph 3 of the amended petition identifying the specific amounts in dispute are limited to the deficiencies and additions to tax set forth in the deficiency notices for 1991 and 1992.4 Paragraph 4 of the amended petition provides in its entirety as follows: AS Reads $6,067.00 SHOULD BE 00 AS READS $823.00 SHOULD BE 0 AS READS $3,844.00 SHOULD BE -0- AS READS $730.00 SHOULD BE -0- Disagreement is based on I.R.C. Sections 3121(a)(7)(A) and 3121 (b)(3)(B) and refundable under I.R.C. Section 3503. Also see Subsection 7806(b) I.R.C. 6343(a)(D) Respondent's Rule 40 Motion and Subsequent Developments 3 We understand this citation to refer to sec. 1-207 of the Uniform Commercial Code. That section is entitled "Performance or Acceptance Under Reservation of Rights" and the current version thereof appears as Nev. Rev. Stat. sec. 104.1207 (1993). 4 Respondent states that she is unaware of any notices of deficiency or collection actions pending against petitioner other than the notices of deficiency for 1991 and 1992. Under the circumstances, we conclude that the Court's jurisdiction in this case is limited to petitioner's liability for the taxable years 1991 and 1992.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011