Scott R. Philips - Page 4

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          REVENUE TAXABLE EVENT WITHIN THE PURVIEW OF THE INTERNAL REVENUE            
          CODE."                                                                      
               On June 14, 1994, the Court ordered petitioner to file an              
          amended petition by August 15, 1994.  In response, petitioner               
          submitted on August 11, 1994, the same defective petition that              
          had been rejected by the Court on June 14, 1994 (except that it             
          bore a new date).  On October 13, 1994, respondent filed a Motion           
          to Dismiss for Failure to State a Claim upon Which Relief Can Be            
          Granted.  In its motion, respondent also asked the Court to                 
          impose a penalty pursuant to section 6673.                                  
               On October 14, 1994, the Court issued an order directing               
          petitioner to file a written objection setting forth clear and              
          concise reasons why respondent's motion to dismiss should not be            
          granted or, in the alternative, setting forth clear and concise             
          allegations of error and facts concerning the merits of the                 
          specific adjustments contained in the notices of deficiency.  In            
          its order, the Court also advised petitioner that penalties have            
          been imposed under section 6673 in similar cases.                           
               On November 14, 1994, petitioner filed a second amended                
          petition that complied with the Court's form and content                    
          requirements.  Accordingly, the Court denied respondent's Motion            
          to Dismiss on November 21, 1994.                                            








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