Arthur B. Crozier - Page 7

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          Commissioner, 85 T.C. 527, 529 (1985); Jacklin v. Commissioner,             
          79 T.C. 340, 344 (1982).                                                    
               The burden of proof is on petitioner to establish that the             
          determinations in the notice are erroneous.  Rule 142(a); Welch             
          v. Helvering, 290 U.S. 111, 115 (1933).                                     
               Petitioner is deemed to have admitted that he received the             
          wage, self-employment, and interest income determined in the                
          notice.  Petitioner is also deemed to have admitted that he                 
          failed to file a return for 1991 and that that failure was                  
          because of willful neglect.  Based on the deemed admissions in              
          this case, and taking account of petitioner's failure to set                
          forth facts showing that he is entitled to any deductions or                
          exemptions other than those allowed in the notice, we conclude              
          that respondent has satisfied her burden of proving that no                 
          genuine issue of material fact exists as to respondent's determi-           
          nations for 1991 and that respondent is entitled as a matter of             
          law to a decision thereon.  Accordingly, we shall grant respon-             
          dent's motion.  Rule 121; Marshall v. Commissioner, supra at 272.           
               To reflect the foregoing,                                              


                                        An appropriate order granting                 
                                   respondent's motion for summary                    
                                   judgment and decision will be                      
                                   entered for respondent.                            






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