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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:
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