Jimmie R. Valentine - Page 2

                                        - 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.                                  




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