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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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