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and (7) petitioners were entitled to a deduction of $3,000 for a
long-term capital loss.
At the initial hearing petitioner contended that a payment
to the Internal Revenue Service in November2 1996 of $2,524 had
been made by his wife for the taxable year 1994 and that that
amount should have been credited to the 1996 liability. It
appears that changes were made to petitioners’ 1994 tax liability
resulting in an underpayment against which a $2,524 payment was
made in 1996 and applied to the 1994 liability. The Court
explained at that time that the taxable year 1994 was not before
the Court. When petitioner later renewed this issue, the Court
pointed out that the 1996 taxable year had not closed at the time
of the payment and a liability for that year had not even been
determined.
The case was continued for trial to the Special Session of
the Court commencing May 17, 2001, in Hartford, Connecticut. On
March 23, 2001, Ms. O’Connor filed a motion to withdraw as
counsel. That motion was granted on March 30, 2001.
Subsequently, petitioner, proceeding pro se, sent various
documents3 to the Court:
2 It is unclear whether the payment was made in September
or November, but the exact date does not appear to be material.
3 Some of the documents received from petitioner have not
been filed and will be placed in the Court’s correspondence file.
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Last modified: May 25, 2011