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determination for 2001 as well as determinations for 1999 and
2000 that petitioner alleged respondent had also made. By order
dated September 29, 2003, we ordered petitioner to file a proper
amended petition and to pay the required filing fee on or before
November 28, 2003. On November 12, 2003, we received and filed
petitioner’s amended petition, which again sought a
redetermination of deficiencies for 1999, 2000, and 2001.
On January 12, 2004, we filed respondent’s motion to dismiss
for lack of jurisdiction and to strike as to petitioner’s 1999
and 2000 taxable years. After receiving an extension of time to
object to the motion, petitioner filed no objection, and we
granted the motion on April 16, 2004.
This case was originally calendared for trial at the New
York, New York, trial session commencing on October 25, 2004.
Following a conference call with the parties, we continued the
case generally.
On April 21, 2005, we filed respondent’s motion for leave to
file amendment to answer to amended petition. In that motion,
respondent acknowledged certain mistakes in the notice of
deficiency and conceded that the correct amount of the income tax
deficiency in the notice of deficiency should have been $5,196.
In addition, respondent alleged that petitioner is liable for an
“increased” deficiency of $5,784.14, for a total deficiency of
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