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understated his income and his tax liability for the
years 1984 and 1985.
[18]. The deficiencies in income tax for the
taxable years 1984 and 1985 are due, in whole or in
part, to the petitioner's fraudulent intent to evade
income tax.
[19]. A part of the underpayment of the tax
required to be shown on the petitioner's income tax
returns for each of the years 1984 and 1985 is due to
fraud.
Petitioner failed to respond to respondent's requests for
admission as required by Rule 90(c). Thereafter, on April 8,
1997, the Court granted petitioner's eighth motion for
continuance to allow petitioner time to recover from an
operation. This case was calendared for trial at the trial
session commencing on September 15, 1997.
On May 13, 1997, respondent filed with the Court a motion
for summary judgment asking that, on the basis of matters deemed
admitted by petitioner as set forth in respondent's requests for
admission, we find petitioner liable for deficiencies and
additions to tax. The Court on May 14, 1997, ordered a response
from petitioner to respondent's motion for summary judgment to be
received or on before June 20, 1997. The order was returned as
unclaimed; petitioner had vacated his last known address without
informing the Court of a change in address as required by Rule
21(b)(4). In addition to failing to respond to the Court's
order, petitioner has not filed any motion to withdraw the deemed
admissions pursuant to Rule 90(f).
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