John S. Black - Page 4

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            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.                                                                              




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