- 4 - 12. In the notice of deficiency respondent determined that petitioner was liable for an [sic] additions to tax pursuant to I.R.C. � 6651(a), in the amount of $9,071.00 in 1992 and $9,534.00 in 1993. 13. Petitioner concedes her liability for the additions to tax under I.R.C. �� [sic] 6651(a) as determined in the notice of deficiency. 14. In the notice of deficiency respondent determined that petitioner was liable for an [sic] additions to tax pursuant to I.R.C. � 6654, in the amount of $1,584.00 for the year 1993. 15. Petitioner concedes her liability for the additions to tax under I.R.C. � 6654 as determined in the notice of deficiency. 16. Petitioner concedes that the adjustments made in the statutory notice of deficiency are in all respects complete and correct. 17. Petitioner is not entitled to any of the deductions listed in her petition. This case was calendared for trial at a prior trial session of the Court. Petitioner appeared at the call of the prior calendar and moved for a continuance, citing her own illness, her son's illness, and the fact that her accountant was "about 95 percent finished" preparing her 1992 and 1993 Federal income tax returns. The Court granted petitioner's motion for continuance but pointed out to petitioner that respondent's requests for admissions "are deemed to be facts under our rules and you didn't respond to them." In response, petitioner did not advancePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011