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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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Last modified: May 25, 2011