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The deficiencies determined by respondent in this case arise
from a reconstruction of petitioner's taxable income because of
petitioner's failure to provide respondent with adequate records
or file income tax returns for the taxable years in issue. The
factual allegations deemed admitted by petitioner under Rule
90(c) establish: (1) Petitioner received taxable income during
the years in issue in the amounts determined in the notice of
deficiency; (2) petitioner failed to establish reasonable cause
for his failure to file income tax returns and has provided no
basis for his failure to pay estimated taxes during the years in
issue; (3) petitioner is liable for the addition to tax pursuant
to section 6653(a)(1) for the taxable year 1988; and (4)
petitioner is liable for the deficiencies and additions to tax
for the years in issue as determined by respondent in the notice
of deficiency.
In sum, the factual allegations deemed admitted by
petitioner under Rule 90(c) establish that respondent's
determinations with respect to petitioner's liabilities for the
deficiencies and additions to tax for the taxable years 1988
through 1993 are correct, and we so hold.
In the absence of any dispute as to a material fact in this
case, we will grant respondent's Motion for Summary Judgment.
To reflect the foregoing,
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