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Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Petitioner filed a petition on June 22, 1995. At that time
petitioner resided in Portland, Oregon. In the petition,
petitioner states the basis of her disagreement with respondent
for each year in issue. Petitioner claims that respondent has
attributed to her more income than she has earned and has allowed
her far less expense than she has incurred and is allowed to
deduct. In the petition, petitioner states that the relevant
notices of deficiency are attached thereto. In the answer,
respondent denies for lack of knowledge that complete copies of
the notices of deficiency are attached to the petition. There
are four separate pages attached to the petition, each dated
March 20, 1995, each titled “NOTICE OF DEFICIENCY”, and each
setting forth the amounts of deficiencies and penalties
(additions to tax) for two or more of the years in issue. Each
page carries at the bottom the notation “(continued next page)”,
but no additional pages are attached to the petition.
Prior to the trial in this case, which was held in Portland,
Oregon, on May 21, 1996, petitioner filed, among other motions, a
motion to dismiss, a motion for sanctions against respondent for
failure to litigate in good faith, and a motion for continuance
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Last modified: May 25, 2011