Charles E. Campbell - Page 2

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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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