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Upon review of petitioner's second amended petition, the
Court recognized that although the allegations discussed above
might possibly constitute assignments of error as required under
Rule 34(b)(4), petitioner nonetheless failed to adequately
articulate the facts supporting these assignments of error as
required under Rule 34(b)(5). In this regard, by Order dated
September 7, 1995, we directed petitioner to file an amendment to
his second amended petition, on or before September 29, 1995,
setting forth clear and concise statements of the facts on which
petitioner bases the assignments of error. More specifically, to
the extent that petitioner contends that he did not earn
nonemployee compensation during the years in issue, petitioner
was directed to identify any and all corporate stock that he
purportedly received as compensation for services rendered during
the years in issue by listing the issuer of such stock, date of
issuance, number of shares, and any and all restrictions imposed
upon petitioner in respect of such stock, i.e., any restrictions
limiting transfer of the stock or any limitation posing a
substantial risk of forfeiture of the stock. Sec. 1.83-3(b),
Income Tax Regs. In addition, petitioner was directed to state
the facts supporting his contention that he engaged in a like-
kind exchange with respect to the notes and contracts of sale
that respondent determined were sold during the years in issue.
Petitioner was directed to specifically identify: (1) Both the
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