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should not be accepted as established. Respondent attached a
proposed First Stipulation of Facts to the motion. The Court,
pursuant to Rule 91(f), granted respondent's motion and issued an
order requiring petitioner, on or before August 9, 1996, to show
cause why the facts and evidence set forth in the stipulation
should not be accepted as established for purposes of this case.
Petitioner failed to comply with the order. As a result, by
order dated September 4, 1996, the Court deemed the facts
admitted for purposes of this case.
Petitioner maintained brokerage accounts at BC Financial
Corp. and Habersheir Securities, Inc. During 1989, petitioner
received $104,147 in proceeds from the sale of stock held in
these accounts. During this same period, petitioner received
interest income of $67 and $64 from New England Mutual Life
Insurance Co. and Dollar Bank, respectively. Petitioner did not
file a 1989 Federal income tax return.
On April 10, 1995, respondent issued petitioner a notice of
deficiency in which she determined that petitioner was liable for
a deficiency of $35,648 for 1989. She also determined that
petitioner was liable for additions to tax for failure to file a
timely return and for failure to make estimated income tax
payments.
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