Paul Garfinkle - Page 2

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               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 the                   







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