- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011