- 4 -
Second, respondent determined that petitioner had failed to
report income in the amount of $4,958.
Third, respondent determined that petitioner was entitled to
an additional deduction for interest expense in the amount of
$6,239.
Finally, respondent made certain mechanical adjustments for
miscellaneous itemized deductions and self-employment tax.
On February 20, 1997, petitioner filed a timely petition
with the Court disputing the deficiency in tax, as well as
claiming an overpayment in the amount of $96,408. In the
petition, petitioner alleged that the notice of deficiency was
based on incorrect conclusions and that petitioner possessed
certain documents to support his position on “capital losses,
charitable contributions, and investment interest”. Petitioner
did not, however, allege any specific errors committed by
respondent in the determination of the deficiency or any specific
facts relating to his claim of an overpayment.
Respondent filed an answer on April 9, 1997.
Petitioner’s case was initially calendared for trial at a
trial session commencing in November 1997. In October 1997,
respondent filed a motion for general continuance. Respondent
asserted that additional time was needed to verify whether
petitioner was entitled to certain newly claimed deductions not
raised by petitioner in the petition. In particular, respondent
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011