- 2 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011