Eric Jennings - Page 4

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           for the taxable years 1993 and 1994, respondent determined that                            
           petitioner's filing status was single.  See sec. 1(c) and (d).                             
                  Petitioner received both notices of deficiency on or about                          
           December 23, 1996.                                                                         
                  On March 13, 1997, petitioner filed a petition (the                                 
           Petition) with the Court.  Paragraph 1. of the Petition states                             
           that petitioner disagrees with the deficiencies for the taxable                            
           years 1993 and 1994.  Paragraph 3. of the Petition states that                             
           petitioner disputes the following:                                                         
             Taxable Year Disputed     Deficiency Disputed       Addition/Penalty Disputed            

             1993                      $47,492                   [1]$19,088                           
             1994                      54,799                    10,960                               

                  1   This figure represents the sum of $9,590, the addition to tax under             
           sec. 6651, and $9,498, the accuracy-related penalty under                                  
           sec. 6662.                                                                                 
           Petitioner attached to the Petition a complete copy of the notice                          
           of deficiency for the taxable years 1993 and 1994.  Petitioner                             
           did not attach to the Petition a copy of the notice of deficiency                          
           for the taxable year 1992, nor did petitioner place in dispute                             
           such taxable year in the Petition.  In fact, neither the taxable                           
           year 1992 nor the deficiency, addition to tax, or accuracy-                                
           related penalty determined by respondent for that year is                                  
           discussed or even mentioned in the Petition.                                               
                  On June 23, 1997, petitioner filed his Motion for Leave to                          
           File Amended Pleading and lodged an Amended Petition (the Amended                          





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