- 7 - On August 28, 2000, petitioner moved for leave to amend the petition. Petitioner’s motion was granted, and the amended petition accompanying the motion was filed on August 30, 2000. The amended petition alleges that respondent failed to consider the tax returns for the taxable years 1994, 1995, and 1996 that petitioner had submitted to respondent on July 7, 2000. Attached to the amended petition are copies of the tax returns for 1994, 1995, and 1996. The tax returns are computed using the married filing jointly filing status and are signed by petitioner and his wife, Rafaela B. Lopez. The attached 1994 tax return is purportedly an amended return and is signed with dates of June 18 and 20, 1996. On September 11, 2000, respondent filed a motion to show cause why proposed facts in evidence should not be accepted as established. The motion sets forth allegations regarding petitioner’s lack of cooperation with respondent. The Court entered an order to show cause on September 15, 2000. Due to a response from petitioner’s counsel alleging ongoing negotiations and the subsequently filed supplemental stipulation of facts, the order to show cause was discharged on October 12, 2000. Respondent filed an answer to petitioner’s amended petition on September 19, 2000. Respondent’s answer to amended petition asserted increased deficiencies and additions to tax pursuant to section 6214(a) as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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