- 3 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011