- 4 - 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 AmendedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011