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contained frivolous and groundless statements, contentions, and
arguments.
On March 19, 2004, the Court granted petitioner’s motion to
remove the small tax case designation and ordered respondent to
file an answer to the amended petition on or before April 19,
2004.
On March 25, 2004, petitioner filed a notice of
nonacquiescence to the March 17 order and a motion for
continuance.
On March 30, 2004, the Court denied petitioner’s motion for
continuance.
On April 2, 2004, respondent filed an answer. In the
answer, respondent affirmatively alleged that (1) he received a
proposed set of stipulations from petitioner, (2) petitioner
attached a Form W-2, Wage and Tax Statement, for 1997 from
Enterprise Network Systems, Inc., listing petitioner’s name and
address and $37,019.21 in wages paid to petitioner, (3) the Form
W-2 has a typographical error in which the numerals in
petitioner’s Social Security number have been transposed, (4) on
the basis of petitioner’s admission of receipt of this income in
his amended petition and the Form W-2 respondent proposed an
increased deficiency for petitioner for 1997, and (5) the total
deficiency for 1997 is $12,006. Additionally, upon the basis of
the additional unreported income from Enterprise Network Sys.,
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