Suzanne F. Mottola - Page 3

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             service, or at any other time.  Accordingly, pursuant to                 
             Rule 90(c), each matter set forth therein was deemed                     
             admitted.  See Freedson v. Commissioner, 65 T.C. 333,                    
             334-336 (1975), affd. 565 F.2d 954 (5th Cir. 1978).                      
             Petitioner is deemed to have made the following admissions:              

                  1.   Petitioner has not filed federal income tax                    
                       returns for the taxable years 1992 and 1993.                   
                  2.   Petitioner was engaged in a trade or business                  
                       during 1992 and 1993.                                          
                  3.   Petitioner failed to maintain any records                      
                       reflecting the income and expenses of her trade                
                       or business.                                                   
                  4.   During 1992 petitioner made total deposits of                  
                       $104,090.44 into her bank accounts.                            
                  5.   Of the net deposits into their [sic] accounts                  
                       in 1992, $0.00 represented non-taxable items.                  
                  6.   During 1993 petitioner made total deposits of                  
                       $101,558.00 into her bank accounts.                            
                  7.   Of the net deposits into her accounts in 1993,                 
                       $0.00 represented non-taxable items such as                    
                       returned checks.                                               
                  8.   Petitioner did not deposit all of her business                 
                       income into her bank accounts.                                 
                  9.   The entire amount of the deposits into                         
                       petitioner's bank accounts in 1992 and 1993                    
                       represented taxable income.                                    
                  10. Petitioner had no other non-taxable sources for                 
                       the deposits made into her bank accounts.                      
                  11. During the years 1992 and 1993 petitioners [sic]                
                       failed to maintain complete and accurate records               
                       of their [sic] income.                                         





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