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year, by delinquently filing his 1993 return in late
May, 1994, and then delaying the payment of his 1993
admitted tax liability throughout 1994, while making
large expenditures for real estate and other assets.
al). Despite the petitioner’s arrest in 1995 and
respondent’s I.R.C. � 6861 jeopardy assessment and
immediate collection action against him, petitioner has
still failed to file any 1994 federal income tax return
reflecting his illegal income.
am). Petitioner fraudulently failed to file a
federal income tax return for the taxable year 1994.
an). All of the underpayment of tax required to
be shown on petitioner’s federal income tax return for
the taxable year 1994 is due to fraud.
On November 21, 1996, the Court served its notice setting
this case for trial at the Court's April 28, 1997, Tampa,
Florida, trial session. The notice setting the case for trial,
in pertinent part, states: “YOUR FAILURE TO APPEAR MAY RESULT IN
DISMISSAL OF THE CASE AND ENTRY OF DECISION AGAINST YOU. * * *
YOUR FAILURE TO COOPERATE MAY ALSO RESULT IN DISMISSAL OF THE
CASE AND ENTRY OF DECISION AGAINST YOU.”
On December 9, 1996, the Court filed respondent's motion for
judgment on the pleadings, in which respondent moved, "pursuant
to the provisions of Tax Court Rule 120", for "an adjudication of
this case in respondent's favor, based upon the respondent's
pleadings as deemed admitted." On December 12, 1996, the Court
ordered petitioner to file, on or before January 10, 1997, a
response to respondent's motion. The Court has never received a
response from petitioner to respondent's motion.
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