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6651(b)(1) for failure to file a timely Federal income tax
return.1
Respondent filed with the Court and served on petitioner a
request for admissions. Petitioner failed to deny or object to
any of the requests for admissions. By failing to respond,
petitioner is deemed to have admitted, pursuant to Rule 90(c),2
the following facts.
Petitioner was a bookkeeper for Nick's Auto during taxable
years 1987 and part of 1988 and for Commander Construction during
part of 1988. Petitioner was also a tax return preparer during
the years at issue. Petitioner was aware of what constituted
allowable deductions.
Petitioner failed to report income from her business and
embezzlement activities. Specifically, petitioner failed to
report wages from Nick's Auto in the amounts of $11,840 and
1Although petitioner filed no reply to the answer,
respondent did not move that the allegations be deemed admitted,
and the allegations in the answer are treated as denied pursuant
to Rule 37(c).
2The relevant part of Rule 90(c) provides as follows:
Each matter [contained in a written request for
admission] is deemed admitted unless, within 30 days
after service of the request or within such shorter or
longer time as the Court may allow, the party to whom
the request is directed serves upon the requesting
party (1) a written answer specifically admitting or
denying the matter involved in whole or in part, or
asserting that it cannot be truthfully admitted or
denied and setting forth in detail the reasons why
this is so, or (2) an objection, stating in detail the
reasons therefor. * * *
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Last modified: May 25, 2011