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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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Last modified: May 25, 2011