- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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