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Background
Respondent issued a notice of deficiency to Lloyd D.
Shepherd (petitioner) determining deficiencies in and additions
to his Federal income taxes for the taxable years and in the
amounts as follows:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a) 6653(a)(1) 6654
1988 $4,994 $1,248.50 $249.70 $320.74
1989 5,553 1,388.25 -- 376.04
1990 5,385 1,346.25 -- 393.91
1991 5,811 1,452.75 -- 334.24
1992 5,722 1,430.50 -- 249.56
1993 3,449 862.25 -- 144.50
The notice of deficiency includes an explanation that, in the
absence of adequate records, respondent reconstructed
petitioner's taxable income for the years in issue based upon an
indirect method of proof.
Petitioner invoked this Court's jurisdiction by filing a
timely petition for redetermination.2 Respondent filed a timely
answer to the petition.
Respondent subsequently served petitioner with a request for
admissions (with attached exhibits) pursuant to Rule 90(a), and
filed the same with the Court pursuant to Rule 90(b). Petitioner
failed to respond to respondent's request for admissions. As a
consequence, each matter set forth therein is deemed admitted
2 At the time that the petition was filed, petitioner
resided at Union City, Indiana.
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Last modified: May 25, 2011