- 2 - Respondent's motion for summary judgment is based on matters deemed admitted by reason of petitioner's failure to respond to requests for admission served by respondent under Rule 90. Respondent determined deficiencies for 1987 through 1989 based on petitioner's failure to file Federal income tax returns and report gross income received from the following activities: gambling, sale of illegal narcotics, and the purchase, repair, and sale of used automobiles. The resulting deficiencies in income tax and additions thereto are as follows: Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6651(f) 1987 $23,320 $17,490 50% of the --- --- interest due on $23,320 1988 18,554 --- --- $13,916 --- 1989 9,658 --- --- --- $7,244 Respondent asserts in the alternative that petitioner is liable for the additions to tax under sections 6651(a) and 6653(a)(1)(A) and (B) for 1987, sections 6651(a) and 6653(a)(1) for 1988, and section 6651(a) for 1989. Based on matters deemed admitted, respondent claims that there is no genuine issue of material fact as to either petitioner's liability for deficiencies in his 1987 through 1989 Federal income tax or petitioner's liability for the fraud additions under sections 6653(b)(1)(A) and (B) for 1987, sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011