Bruce M. Crow - Page 7

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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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