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determined the amount of each income adjustment from information
provided by reporting third parties, and the amounts were
established by means of deemed admissions under Rule 90. One of
the items of income may be the gross proceeds of a security sale;
however, petitioner did not wish to provide any evidence,
including whether he had any basis in the security sold so as to
reduce the amount of tax liability.
Respondent also determined additions to tax in each year
under sections 6651(a) (failure to file) and 6654(a) (failure to
pay estimated tax). It is clear from the information available
in this case that petitioner failed to file a return. In
addition, petitioner has offered no evidence or sound
explanations as to why these additions to tax should not be
imposed. In view of the foregoing, we hold that the additions to
tax under sections 6651(a) and 6654(a) are sustained for the
taxable years 1991 and 1992. Rule 142(a); New Colonial Ice Co.
v. Helvering, 292 U.S. 435 (1934); Welch v. Helvering, 290 U.S.
111 (1933).
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011