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case, and that she is deemed to have admitted that she is liable
for fraud under Rule 37(c).
We decide this motion based on the parties' pleadings,
admissions, and written submissions. For reasons stated below,
we grant respondent's motion.
Background
Petitioner was incarcerated in Alderson, West Virginia, when
she filed the petition in this case.
Respondent determined deficiencies in petitioner’s income
tax and additions to tax and a penalty as follows:
Additions To Tax and Penalty
Year Deficiency Sec. 6653(b)(1) Sec. 6661 Sec. 6663
1988 $48,308 $36,104 $12,035 --
1989 58,190 -- -- $43,643
Petitioner filed her petition on March 3, 1994. In it, she
stated that she would be released from prison in January 1995.
She asked that we delay proceedings until after she was released
from prison. She filed an amended petition on May 23, 1994.
On July 15, 1994, respondent filed an answer to petitioner's
amended petition. In it, respondent alleged:
6. FURTHER ANSWERING the petition, and in support of
the determination that the underpayments of tax
required to be shown on the petitioner's 1988 and 1989
income tax returns are due to fraud, under the
provisions of I.R.C. � 6653(b)(1) and 6663,
respectively, the respondent alleges:
(a) During the taxable years 1988 and 1989, petitioner
was employed as a civilian fiscal accounting clerk
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