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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1992 $36,284 $9,071 --
1993 38,134 9,534 $1,584
All section references are to the Internal Revenue Code in
effect during the years in issue.
During the years in issue, petitioner was a self-
employed attorney. At the time she filed her petition in
this case, petitioner resided in Devon, Pennsylvania.
Petitioner failed to file Federal income tax returns
for the years 1992 and 1993. She did not maintain adequate
books and records from which her tax liability for those
years could be computed. Accordingly, respondent used
the bank deposits method to reconstruct petitioner's income
and determined the above tax deficiencies and additions to
tax in a notice of deficiency issued to petitioner.
Respondent served a request for admissions on
petitioner. Rule 90(c) of the Tax Court Rules of Practice
and Procedure states that "Each matter is deemed admitted
unless, within 30 days after service of the request * * *
the party to whom the request is directed serves upon the
requesting party: (1) a written answer * * * or (2) an
objection, stating in detail the reasons therefor." All
Rule references are to the Tax Court Rules of Practice
and Procedure. Petitioner did not respond or object to
respondent's request for admissions within 30 days after
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Last modified: May 25, 2011