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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.
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