- 3 - For clarity and convenience, our findings of fact and opinion have been combined. After receiving the statutory notice of deficiency in this case, petitioner sent a letter to the Court requesting information. This letter was filed as a petition. The Court ordered petitioner to file an amended petition, and he did so. In his amended petition, petitioner stated that he "disagrees with the tax deficiencies for the years 1990 and 1991 as set forth in the alleged NOTICE OF DEFICIENCY dated January 27, 1994, a copy of which is attached and identified as EXHIBIT A." Petitioner went on to state: 4. Petitioner denies all deficiencies and all addition [sic] to the alleged tax: a. The alleged Notice of Deficiency issued is not a true and/or proper Notice of Deficiency. b. There are no math errors. c. I have no liability for a non-master file tax. d. I am not a non-resident alien, foreign corporation, foreign partnership, or foreign estate or trust. Respondent subsequently filed a Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted pursuant to Rule 40. Thereafter, the Court issued an order calendaring respondent's motion for hearing, and also directing petitioner to file a proper second amended petition before the hearing. Specifically, the Court directed petitioner to file aPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011