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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, section
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