Craig A. Bratcher - Page 6

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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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