- 4 - from Frank Perrotti and Sons, Inc. and Peoples Bank, respectively, which were not reported on his returns. m. The petitioner failed to file an income tax return for the 1991 taxable year, even though he had substantial income which required him to file a return. n. The petitioner failed to accurately report his income, when he filed his income tax returns for the 1992 and 1993 taxable years. o. The petitioner's failure to file his 1991 [return] and to report gross income in the amount of $365,464.00 and taxes due in the amount of $80,822.57 were fraudulent with the intent to evade taxes. p. The petitioner's failure to report gross income in the amounts of $268,031.00 and $157,467.00 for the 1992 and 1993 taxable years, respectively, was fraudulent with the intent to evade taxes. [q]. The petitioner's understatement of his federal tax liabilities in the amounts of $76,176.58 and $53,683.19 for the 1992 and 1993 taxable years, respectively, was fraudulent with the intent to evade taxes. [r]. A part of the underpayment of tax required to be shown on the petitioner's federal income tax returns for each of the taxable years 1991, 1992 and 1993 is due to fraud with the intent to evade taxes. On January 2, 1998, respondent filed a request for admissions with the Court, a copy of which respondent had served on petitioner on December 30, 1997. Petitioner did not file any response to the request for admissions. As a result, each matter set forth therein is deemed admitted.1 Rule 90(c); Marshall v. Commissioner, 85 T.C. 267, 272 (1985). 1 The request for admissions reiterates many of the facts alleged in the answer that were deemed admitted.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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