- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011