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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