- 5 - Inc., not contained in the notice of deficiency, respondent also asserted that the total additions to tax pursuant to sections 6651(a) and 6654(a) are $3,001.50 and $642.33, respectively. That same day, petitioner filed a motion to shift the burden of proof to respondent pursuant to section 7491 and a motion for interlocutory review of the March 17 order. On April 9, 2004, petitioner filed a notice of refusal to stipulate. On April 13, 2004, the Court denied petitioner’s motion for interlocutory review. In order to give petitioner time to file a reply to the answer, the Court also ordered this case stricken from the Court’s Dallas, Texas, session beginning April 26, 2004, and continued it generally. On April 22, 2004, petitioner filed a motion for stay, an objection regarding the docket sheet, a second motion for judgment on the pleadings, and a motion for interlocutory appeal. In the objection, petitioner objected to the capitalization of certain letters of his name and to the address listing petitioner as a “resident” of a State “via the identifier of ‘TX.’” Petitioner claimed he was not a resident of that State. In his objection regarding the docket sheet, beneath his signature, petitioner listed his address as 1908 Vassar Drive, Richardson, Texas 75081. This is the same address that petitioner had listed in his imperfect petition.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011