Lloyd D. Shepherd - Page 4

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          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             





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