Richard John Florance, Jr. - Page 4

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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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