Frederick M. Fox - Page 4

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                    C.        Respondent's Request for Admissions and Petitioner's                                                                                         
                              Responses                                                                                                                                    
                              On June 5, 1997, respondent served a request for admissions                                                                                  
                    on petitioner under Rule 90.  Respondent's request for admissions                                                                                      
                    and petitioner's responses are as follows:                                                                                                             
                              1.  Petitioner admits that he did not file a U.S.                                                                                            
                    Individual Income Tax Return, Form 1040, for 1989, 1990, 1991 and                                                                                      
                    1992.                                                                                                                                                  
                              2.  Petitioner admits that from 1989 to 1992 he received:                                                                                    
                    (a) Compensation for services as an airline pilot for American                                                                                         
                    Airlines in the amounts of $149,663, $150,708, $176,719, and                                                                                           
                    $155,171; (b) interest income from the American Airlines Credit                                                                                        
                    Union in the amounts of $521, $147, $409, and $587; and (c)                                                                                            
                    dividend income from various Merrill Lynch accounts in the                                                                                             
                    amounts of $853, $905, $1,075, and $457.  Petitioner denies that                                                                                       
                    this income is taxable.  Petitioner's response also includes the                                                                                       
                    word "jurisdiction" without explanation.  We assume this (and                                                                                          
                    other unexplained references to "jurisdiction" in petitioner's                                                                                         
                    response to respondent's request for admissions) relates to                                                                                            
                    petitioner's contention in his petition that the Commissioner                                                                                          
                    lacked jurisdiction to issue the notices of deficiency.                                                                                                
                              3.  Petitioner admits that he received:  (a) Capital gain                                                                                    
                    income from various Merrill Lynch accounts totaling $4,754 in                                                                                          
                    1989; and (b) income of $88 from the sale of stock from                                                                                                
                    Merrill Lynch in 1990, and $2,786 in 1991.  Petitioner denies                                                                                          




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