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Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B) 6661
1985 $18,982 $9,491 1 --- --- $4,584
1986 25,986 --- --- $19,490 1 6,497
1987 41,712 --- --- 31,284 1 ---
1 50 percent of the interest due on the deficiency.
Background
Petitioner invoked the jurisdiction of this Court on
February 20, 1996, by timely filing a petition. Petitioner
resided in Columbus, Ohio, at the time the petition was filed.
On April 24, 1996, respondent timely filed an answer to the
petition denying that respondent erred with respect to the
determinations set forth in the deficiency notice. Respondent's
answer includes specific allegations in support of the
determination that petitioner is liable for additions to tax for
fraud for the years in issue. Petitioner failed to file a reply
denying the allegations contained in respondent's answer. Thus,
on June 17, 1996, respondent filed a motion under Rule 37(c) to
have the undenied allegations of fact deemed admitted.
Petitioner was notified of the filing of respondent's Rule 37(c)
motion by notice of filing dated June 17, 1996. Petitioner
failed to respond to the notice of filing and failed to file a
reply to respondent's answer. We granted respondent's motion on
July 15, 1996.
Respondent's answer reads, in pertinent part, as follows:
8. FURTHER ANSWERING the petition, and in support
of the determination that a part of the underpayment of
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