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Respondent determined petitioner had a deficiency in tax of
$43,866 for 2001, which included self-employment tax of $13,511.
Respondent also determined petitioner was liable for additions to
tax under sections 6651(a)(1) and 6654(a) of $10,072 and $1,754,
respectively.
On February 5, 2004, the Court filed petitioner’s imperfect
petition. By order dated February 9, 2004, the Court ordered
petitioner to file a proper amended petition and pay the filing
fee on or before March 25, 2004. The Court received petitioner’s
filing fee on March 29, 2004, but did not receive a proper
amended petition. By order dated June 2, 2004, the Court
extended the time to file a proper amended petition to June 30,
2004. No response to the Court’s June 2, 2004, order was
received, and on August 13, 2004, the Court dismissed
petitioner’s case for lack of jurisdiction.
On November 12, 2004, the Court filed petitioner’s motion to
vacate the order of dismissal. Petitioner attached an amended
petition to his motion. On November 12, 2004, the Court granted
petitioner’s motion, vacated the order of dismissal, and filed
petitioner’s amended petition.
A notice setting case for trial during the Court’s
Cleveland, Ohio, trial session beginning March 27, 2006, was
served on petitioner on October 21, 2005. By order dated March
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