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On July 19, 1995, shortly after respondent filed her motion
to dismiss, the Court issued an order calendaring respondent's
motion for hearing and also directing petitioner to file a proper
amended petition in accordance with the requirements of Rule 34.
In particular, the Court directed petitioner to file a proper
amended petition setting forth with specificity each error
allegedly made by respondent in the determination of the
deficiencies and separate statements of every fact upon which the
assignments of error are based.
On July 20, 1995, petitioner filed an Opposition to
Respondent's Motion to Dismiss and the following 6 motions: (1)
Motion for Equal Protection and Uniform Procedure; (2) Motion for
Re-Determination; (3) Motion to Compel Performance; (3) Motion
for More Definite Statement; (4) Motion to Strike Respondent's
Motion to Dismiss; (5) Motion for Summary Judgment; and (6) a
second Motion for Summary Judgment. All of petitioner's motions
were denied. Petitioner's Opposition includes the following
statement:
While Petitioner has not denied receiving
compensation for services, the Petitioner DOES deny
that the Law makes said compensation includible in
[gross] "income." Regardless of whether or not such
amounts are gross income or, because Congress chose to
not so include the FMV of Petitioner's personal
property, the Law does not permit the inclusion in
income now attempted by the Respondent; how have ALL
applicable statutes operated?
On August 2, 1995, petitioner filed the following 3 motions:
(1) Motion for More Definite Statement; (2) Motion for Calendar
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