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respondent requested that petitioner determine how she wanted to
resolve this case. In a subsequent conversation with respondent,
petitioner indicated that she had received the letter.
In another conversation, petitioner notified respondent that
she would not sign a proposed decision document to resolve this
case and that she did not plan to attend the calendar call in Los
Angeles, California. Based on this information, respondent
informed petitioner that respondent planned to file, at the
calendar call in Los Angeles, California, a Motion to Dismiss for
Lack of Prosecution with regard to petitioner.
Shortly before the case was called for trial, respondent
filed with the Court a Motion for Leave to File Amendment to
Answer and lodged the Amendment to Answer. The Court granted
respondent's Motion for Leave to File Amendment to Answer. In
the Amendment to Answer, respondent notified the Court of the
clerical error in the notice of deficiency. The Amendment to
Answer also stated that the deficiency asserted for the tax year
1982 was in the amount of $29,913. The original deficiency for
the 1982 tax year was $38,782; however, the settlement of the
Kelsey/Soda Lake Mining tax shelter issue reduced the 1982
deficiency to $29,913.
When this case was called for trial in Los Angeles,
California, petitioner did not appear. At the calendar call,
respondent filed with the Court, on behalf of petitioner
Dennis P. Raquet, a Stipulation of Settlement between Respondent
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