- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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