David White - Page 3

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          paid by Alger Money Market Portfolio; (4) gains derived from                 
          stock/bond sales in 1992; and (5) prizes and awards received from            
          Lincoln Investment Plan in 1994.  Those items of income were                 
          reported to respondent on Forms 1099 and other information                   
          returns submitted by the payors.                                             
               Petitioner invoked this Court's jurisdiction by filing an               
          imperfect petition for redetermination, followed by an amended               
          petition.2  The amended petition states in pertinent part:                   
               A. The "Notice" Tax, Penalty, and Interest is in                        
               "error" as indicated in the "Notice of Deficiency”.                     
               B. Petitioner is not liable for said Tax, Penalty, and                  
               Interest as indicated in said Deficiency.                               
               C. Deficiency is based on hearsay information.                          
               In response to the amended petition, respondent filed a                 
          Motion to Dismiss for Failure to State a Claim Upon Which Relief             
          Can Be Granted.  Shortly thereafter, the Court directed                      
          petitioner to file a proper second amended petition setting forth            
          with specificity each error that petitioner alleges was made by              
          respondent in the determination of the deficiencies and additions            
          to tax and separate statements of every fact upon which                      
          petitioner bases the assignments of error.                                   
               Petitioner failed to comply with the Court's order to file a            
          proper second amended petition.  To the contrary, petitioner                 


               2  At the time that the petition was filed, petitioner                  
          resided in Houston, Texas.  Accordingly, this case is appealable             
          to the Court of Appeals for the Fifth Circuit.                               




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