Richard John Florance, Jr. - Page 2

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          Background                                                                  
               By notice of deficiency, respondent determined a deficiency            
          of $3,300 and additions to tax of $825 and $176.55 pursuant to              
          sections 6651(a)(1) and 6654(a), respectively, in petitioner’s              
          1997 Federal income tax.                                                    
               On July 17, 2003, petitioner invoked the jurisdiction of               
          this Court by filing an improper petition.                                  
               On July 21, 2003, the Court ordered petitioner to file a               
          proper amended petition on or before September 19, 2003.                    
               On August 13, 2003, petitioner filed a status report                   
          acknowledging receipt of the Court’s July 21, 2003, order and               
          stating that the case could be resolved without an amended                  
          petition once “Regional or District Counsel” was assigned.                  
               On September 17, 2003, petitioner filed an amended petition.           
          Petitioner requested that this case be conducted under the small            
          tax case procedure.  In the amended petition, petitioner noted              
          that in the notice of deficiency respondent made an adjustment              
          for $15,000 in wages he admitted he received in 1997 but failed             
          to include an additional $37,000 in wages petitioner received               
          during 1997.                                                                
               On December 15, 2003, petitioner filed a motion for judgment           
          on the pleadings.  Petitioner characterized the primary issue in            
          his case as whether he was a “taxpayer” and asserted that he had            
          challenged this issue.  The motion for judgment on the pleadings            






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