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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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