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On January 27, 2006, respondent issued petitioner a notice
of deficiency for 2002. Respondent disallowed petitioner’s
claimed itemized deductions for the charitable contributions and
the unreimbursed employee expenses.2 On the basis of the
disallowance, respondent determined a deficiency in petitioner’s
2002 Federal income tax of $1,953.
In response to the notice of deficiency, petitioner filed a
petition with this Court on May 1, 2006. Contrary to the
requirements of Rule 34(b)(4), the petition did not contain clear
and concise statements of each and every error which petitioner
alleged to have been committed by respondent in the determination
of the deficiency. On May 16, 2006, respondent filed a motion to
dismiss for failure to state a claim upon which relief can be
granted. On May 19, 2006, the Court ordered petitioner to file
an amended petition setting forth with specificity each error
petitioner alleged respondent made in the determination of the
deficiency. On July 10, 2006, petitioner filed a 132-page
amended petition which consisted mainly of allegations of
conspiracy by government agencies and third parties not related
to this suit.
On August 16, 2006, the Court heard arguments on
respondent’s motion to dismiss for failure to state a claim.
2 Respondent also increased petitioner’s child tax credit
from $513 to $600 but reduced the additional child tax credit
from $87 to zero. Petitioner has not disputed this change.
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Last modified: November 10, 2007