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Respondent complied with this Order, but petitioner failed to
respond.
On November 23, 1993, respondent filed her Motion for
Partial Summary Judgment. Respondent seeks partial summary
adjudication of the following issues raised in the notices of
deficiency for taxable years 1975 through 1981: (1) That
petitioner received other or miscellaneous income during 1976,
1977, and 1978 in the respective amounts of $1,684,916,
$2,000,536, and $2,926,612; (2) that petitioner is not entitled
to certain losses from the partnerships S-J Minerals Associates
III, L.P., and G & O Associates for 1976 and 1977; (3) that
petitioner is not entitled to deduct mining losses in the amount
of $10 million for each of the years 1977 through 1980, and in
the amount of $100,000 for 1981; (4) that petitioner is not
entitled to carry forward certain net operating losses to 1976
through 1981; (5) that petitioner is liable for additions to tax
for fraud pursuant to section 6653(b) for the taxable years 1975
through 1981; and (6) that assessment is not time barred for the
years 1975 through 1981.
Because petitioner failed to respond to respondent's
requests for admissions, the facts contained therein are deemed
admitted. Rule 90(c); Marshall v. Commissioner, 85 T.C. 267, 272
(1985); Freedson v. Commissioner, 65 T.C. 333, 334-336 (1975),
affd. on another issue 565 F.2d 954 (5th Cir. 1978). The
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