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$5,998, for the taxable years 1990, 1991, and 1992, respectively.
Additionally, in the Amended Answer to Amended Petition, respon-
dent asserted that petitioner was liable for the addition to tax
for fraud under section 6651(f). In the alternative, respondent
relies on the determination in the notice of deficiency that
petitioner was liable for a 25 percent addition to tax under
section 6651(a)(1).
Petitioner filed a petition in this Court on July 11, 1994.
On December 30, 1994, the case was calendared for trial during
the trial session beginning on June 5, 1995.
On March 8, 1995, this Court granted the parties' first
Joint Motion for Continuance and continued the case for trial
from the June 5, 1995, trial session. Subsequently, on May 25,
1995, the case was again calendared for trial during the trial
session beginning on October 30, 1995. On September 7, 1995, the
Court granted the parties' second Joint Motion for Continuance,
to allow time for petitioner's recovery from brain and spinal
cord injuries. On December 6, 1995, petitioner requested an
additional 90 days in which to answer Respondent's Requests for
Admission (First Admission Request), which had been mailed to
petitioner on October 31, 1995. This Court granted the extension
of time until April 25, 1996.
Respondent's Second Requests for Admission (Second Admission
Request) was mailed to petitioner on May 21, 1996. Petitioner
did not answer either the First Admission Request or the Second
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