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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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