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Donna F. Herbert, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge: Respondent determined a deficiency in
petitioner's Federal income tax in the amount of $426,707, and an
accuracy-related penalty under section 6662(a)2 in the amount of
$85,341 for petitioner's taxable year ended July 31, 1990. Some
1(...continued)
U.S. Tax Court to continue its proceedings involving the debtor
in the bankruptcy case, and allowing the IRS to assess any tax
liability determined by the U.S. Tax Court in the case before it.
On Nov. 6, 1995, this Court issued an order that the stay of
proceedings in this case was lifted and allowed petitioner to and
including Dec. 20, 1995, within which to file a brief in this
case. In a further order dated Nov. 22, 1995, granting Mitchell
R. Miller's motion to withdraw as counsel for petitioner, which
order was served on petitioner, the Court specifically stated
that petitioner was not relieved of the obligation of filing a
brief in this case by Dec. 20, 1995, because of withdrawal of its
counsel.
No brief was received by the Court as required by order of
the Court. By order dated Mar. 18, 1996, we granted petitioner
to and including Apr. 15, 1996, to file a reply to respondent's
brief filed June 21, 1995 (which had been served on petitioner
Jan. 16, 1996), and stated that if no brief were received from
petitioner on or before Apr. 15, 1996, the Court would proceed
with consideration of this case. The Court has received no brief
from petitioner, and, therefore, it has been necessary to
determine the issues in this case without a statement of
petitioner's position with respect to the evidence in the case or
petitioner's position with respect to respondent's requested
findings of fact and arguments in her brief.
2 All section references are to the Internal Revenue Code
in effect for the year in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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