- 6 - 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 $406Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011