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Petitioner timely filed his petition with the Court on July
6, 1998. In his petition, petitioner alleged, in pertinent part:
4. The determination of the tax set forth in said
notice of deficiency is based upon the following
errors:
A. The Commissioner has erroneously
alleged that the petitioner received two
hundred forty-one thousand, six hundred and
fifty-seven dollars, ($241,657), as total
income.
B. The Commissioner has erroneously
alleged that the petitioner received a
capital gain of one hundred thirty-seven
thousand, eight hundred and thirty-five
dollars, ($137,835).
* * * * * * *
D. The Commissioner has erroneously
alleged that the petitioner owes a
delinquency penalty pursuant to Internal
Revenue Code �6651(a)(1) in the amount of
thirteen thousand, one hundred and forty-
three dollars, ($13,143).
E. The Commissioner has erroneously
alleged that petitioner owes a penalty of two
thousand, one hundred fifteen dollars and
sixty-three cents ($2,115.63), for failure to
file adequate quarterly estimates pursuant to
Internal Revenue Code �6654.
Further, petitioner alleges:
5. The facts upon which the petitioner relies, as
the basis of the petitioner’s case, are as follows:
A. To the best of petitioner’s
information, knowledge and belief, the
petitioner’s total income was approximately
one hundred three thousand, eight hundred
seventy-seven dollars and twenty-four cents,
($103,877.24). This is the sum of the
following:
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