- 4 -
of $19,930, $21,599, $21,736, $23,369, $23,221, and $15,201
during the taxable years 1988, 1989, 1990, 1991, 1992, and 1993,
respectively. Petitioner is liable for deficiencies in income
tax in the amounts of $4,994, $5,553, $5,385, $5,811, $5,722, and
$3,449 for the taxable years 1988, 1989, 1990, 1991, 1992, and
1993, respectively.
Petitioner is also deemed to have admitted, pursuant to Rule
90(c), the following matters:
Petitioner has provided no reasonable cause for his failure
to file income tax returns for the taxable years 1988 through
1993. Petitioner is liable for the additions to tax pursuant to
section 6651(a)(1) for each of the years in issue as determined
in the notice of deficiency. Petitioner has provided no basis
for his failure to pay estimated taxes for the taxable years 1988
through 1993. Petitioner is liable for the additions to tax
pursuant to section 6654(a) for each of the years in issue as
determined in the notice of deficiency. Petitioner's failure to
file his tax return for 1988 is due to negligence or disregard of
rules or regulations. Petitioner is liable for the addition to
tax pursuant to section 6653(a)(1) for the taxable year 1988 as
determined in the notice of deficiency.
As indicated, respondent filed a Motion for Summary Judgment
seeking judgment in respondent's favor on all issues. Respondent
contends that the matters deemed admitted in this case pursuant
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011