William Santangelo - Page 8

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          "Motion for More Definite Statement", which was filed as                    
          petitioner's Second Motion for More Definite Statement.                     
               Regarding the documents received August 10, 1995, the Court            
          granted petitioner's Motion for Leave to File Brief in Support of           
          Rule 50(c) Statement, and then filed (a) petitioner's Brief in              
          Support of Rule 50(c) Statement and (b) petitioner's Appendix to            
          Brief in Support of Rule 50(c) Statement.  The Court denied                 
          petitioner's Motion for Summary Judgment and petitioner's Second            
          Motion for More Definite Statement.                                         
               In his Amended Petition and Amendment thereto, as well as in           
          his other most recently filed documents, petitioner repeats many            
          of the allegations set forth in his original petition,                      
          particularly his argument that section 83 shields his                       
          compensation from taxation.6  Thus, the Amendment to the Amended            
          Petition includes the following allegation:                                 
                    Code � 83 applies to all compensation for services                
               and allows only for the excess over the "amount paid"                  
               (value of the Labor) to be included in gross income;                   
               NOT the "amount paid" (cost).  Respondent is in                        
               violation of 26 USC � 83.                                              
          Respondent's motion to dismiss was called for hearing in                    
          Washington, D.C., on August 16, 1995.  Counsel for respondent               
          appeared at the hearing and presented argument on the pending               
          motion, including the argument that section 83 is inapplicable to           


          6 Petitioner appears to have abandoned, however, his                        
          argument that sec. 7701(e) shields his compensation from                    
          taxation.                                                                   




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