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February 24, 1995, the Court granted respondent's motion and
deemed admitted for purposes of this case the undenied
affirmative allegations of fact contained in paragraphs 7 and 8
of respondent's answer. Rule 37(c). On promulgation of our
order the pleadings herein were closed. See Rules 34, 36, 37,
38, 121. The following findings of fact are based upon the
allegations in the answer which are deemed to be admitted.
FINDINGS OF FACT
Petitioner filed Federal income tax returns in 1979, 1980,
and 1981 jointly with his wife (Pamela Marie Tinsley-Cadwell).
Although aware of his filing obligation, petitioner failed to
file timely tax returns for tax years 1983 through 1988,
resulting in the omission of $243,170 of income. During the
years at issue, petitioner received $243,170 in the form of wage
income or self-employment income as follows:
Year Payer Income
1983 Holaday-Parks, Inc. $47,562.74
1984 Holaday-Parks, Inc. 4,777.51
1984 Peter Kiewit Sons Co. 11,923.67
1984 Natkin Sheet Metal Co. 20,183.68
1984 Sun-Air Sheet Metal, Inc. 1,392.33
1984 Toklat Sheet Metal, Inc. 13,078.02
Total 1984 51,355.21
1985 Toklat Sheet Metal, Inc. 39,681.41
1986 Toklat Sheet Metal, Inc. 52,000.62
1987 Toklat Sheet Metal, Inc. 20,987.72
1987 Sandstrom Plumbing & Heating 9,501.36
Total 1987 30,489.08
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