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November 27, 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 second
amended petition in accordance with the requirements of Rule 34.
In particular, the Court directed petitioner to file a second
amended petition setting forth with specificity each error
allegedly made by respondent in the determination of the
deficiency and separate statements of every fact upon which the
assignments of error are based.
Petitioner responded to the Court's Order dated November 27,
1995, by filing a second amended petition on December 29, 1995.
In his second amended petition, petitioner again admits that he
did not file income tax returns for the taxable years in issue
and alleges that respondent's deficiency determinations were not
based on any factual evidence. The second amended petition also
includes the following allegations:
(...continued)
Income 1992
Nonemployee
compensation $27,946
Wages 6,780
Interest ---
Total 34,726
As a consequence of the foregoing, respondent recomputed the
deficiency and the additions to tax for 1992, as follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1992 $9,314 $2,329 $406
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