- 6 -
against petitioner in the amounts set forth in the notice of
deficiency, and consider imposing a penalty against petitioner
under section 6673. Respondent's Motion for Summary Judgment was
continued for further hearing to August 16, 1995, in Washington,
D.C.
On August 8, 1995, petitioner filed a second amended
petition which in large part repeats and expands upon the
arguments found in both his amended petition and his reply to
respondent's answer. Among his various contentions, petitioner
alleged that respondent erred in determining that petitioner
earned nonemployee compensation for the years in issue on the
ground that the compensation in question was paid in the form of
corporate stock subject to section 83. Petitioner also alleged
that respondent erred in determining that he failed to report
unearned income for the years in issue. In particular,
petitioner asserted that the notes and contracts of sale that are
the subject of this adjustment were not sold as respondent
determined but, rather, were the subject of a "like kind
exchange" with an individual identified as James Shinault.
This case was again called for hearing in Washington, D.C.,
on August 16, 1995. Counsel for respondent appeared at the
hearing and presented further argument in support of the pending
motion. Petitioner did not appear at the hearing.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011