- 2 - For 1976, respondent determined a deficiency of $2,268,906 in petitioner's Federal income tax and a fraud addition to tax under section 6653(b) of $1,134,453. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect for the year in issue. When the petition was filed, petitioner resided in Boca Raton, Florida. On March 26, 1990, respondent served petitioner with requests for admission under Rule 90 with respect to significant material facts regarding the alleged unreported income, the disallowed partnership losses, and the fraud addition to tax that were determined by respondent. Petitioner did not answer or object to respondent's requests for admission. Because petitioner failed to respond to respondent's requests for admission, the factual matter set forth in respondent's requests for admission is deemed admitted. Rule 90(c). Petitioner was an intelligent, well-educated individual, and an experienced tax attorney. In 1976, petitioner and an individual named George Osserman organized, promoted, controlled, and invested in a group of tax-oriented limited partnerships hereinafter referred to as the S-J partnerships or as thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011