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relating directly to the determinations made in the notice of
deficiency. Specifically, paragraph 4(A)(1) through (5) for 1992
and paragraph 4(B)(1) through (7) for 1993 contend that
respondent erred in the various specific adjustments. Moreover,
paragraph 5(A)(1) through (5) for 1992 and paragraph 5(B)(1)
through (7) for 1993 clearly allege that petitioner did not
receive the income determined by respondent and that petitioner
is not liable for the deficiencies and additions to tax.
However, the petition contains a paragraph on page 3 which states
the following:
FOR ALL TAX YEARS
(1) Respondent has failed to allege sufficient facts
to establish that Respondent has jurisdiction over
Petitioner in this matter.
(2) By her previous actions, Respondent has attempted
to mislead or has actually misled Petitioner with
respect to the obligation to file tax returns and/or
the obligation to report income.
(3) Respondent failed to provide specific information
as to whether the deficiencies in tax are direct taxes
or indirect (excise) taxes.
As indicated, respondent filed a Motion to Dismiss for
Failure to State A Claim on April 29, 1996. In her motion to
dismiss, respondent contends that the petitioner fails to allege
clear and concise assignments of error in respondent's deficiency
determination in violation of Rule 34(b)(4). Further, respondent
contends that the petitioner fails to allege clear and concise
lettered statements of fact on which petitioner bases assignments
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