Ruth R. Johnson-Straub - Page 2

               This case is before the Court on respondent's Motion To                
          Dismiss For Failure To State A Claim, as supplemented, filed                
          pursuant to Rule 40.                                                        
               Petitioner resided in Cleveland, Ohio, at the time that the            
          petition was filed with the Court.                                          
          Respondent's Notice of Deficiency                                           
               Respondent issued to petitioner a notice of deficiency dated           
          September 13, 1995, in respect of the taxable year 1993, and a              
          notice of deficiency dated November 8, 1995, in respect of the              
          taxable year 1992.  In said notices, respondent determined the              
          following deficiencies in petitioner's Federal income taxes and             
          additions to tax:                                                           
                 Additions to tax                                                     
          Year     Deficiency     Sec. 6651(a)(1)     Sec. 6654(a)                    
          1992     $4,904             $182.50             ---                         
          1993      7,775              875.00            $126.71                      

               The deficiencies in income taxes are based on respondent's             
          determination that petitioner failed to report income as reflected in       
          the following schedules:                                                    

          Practice and Procedure.                                                     

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