- 6 - hearing in this matter from Washington, D.C. to San Francisco, as requested in petitioner's motion filed one day prior to the date of the scheduled hearing, would serve no purpose but to delay the resolution of respondent's motion. Consequently, petitioner's motion will be denied. Respondent's Motion Rule 34(b)(4) requires that a petition filed in this Court contain clear and concise assignments of each and every error that the taxpayer alleges to have been committed by the Commissioner in the determination of the deficiency and the additions to tax in dispute. Rule 34(b)(5) further requires that the petition contain clear and concise statements of the facts on which the taxpayer bases the assignments of error. See Jarvis v. Commissioner, 78 T.C. 646, 658 (1982). The petition filed in this case does not satisfy the requirements of Rule 34(b)(4) and (5). Although petitioner states that he disagrees with respondent’s determinations, there is neither assignment of error nor allegation of fact in support of any assigned error. After having been provided the opportunity to do so, petitioner failed to file a proper amended petition as he was directed to by the Court. The allegations contained in the petition that petitioner has not had an opportunity to meet with respondent to discuss his 1991 Federal income tax liability and that respondent has failed to respond toPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011