- 2 - Additions to Tax Year Deficiency Sec. 6651(a)(1)1 Sec. 6654 1990 $20,709 $5,177 $1,356 1991 19,711 4,928 1,126 1992 8,188 2,047 357 1993 4,940 1,235 207 1994 4,651 1,163 241 We must decide whether the determinations in the notices of deficiency (notices) that respondent issued to petitioner should be sustained. We hold that they should. Petitioner did not comply with the Court's Standing Pretrial Order and did not cooperate with respondent in preparing this case for trial and/or attempting to settle it. Consequently, none of the facts has been stipulated. However, on March 21, 1998, respondent filed a request for admissions with the Court, a copy of which respondent had served on petitioner on February 25, 1998. Petitioner did not file any response to that request for admissions. As a result, each matter set forth therein, including the following, is deemed admitted. Rule 90(c); Marshall v. Commissioner, 85 T.C. 267, 272 (1985). Petitioner resided in San Diego, California, at the time he filed the petition. Petitioner, who was born on October 10, 1928, and who was throughout the years at issue a practicing medical doctor, did 1 All section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011