- 12 - It would serve no useful purpose to recount the deemed admitted facts at length; they are set forth supra pp. 4-6. It suffices to say that they cover all matters set forth in the statutory notice of deficiency that were not disposed of by the Court's prior opinion in this case. We therefore hold that, as a result of the foreclosure of the Calmin Drive property, petitioner Kenneth Anderson had cancellation of indebtedness income of $275,000 in 1992. In the absence of the furnishing by petitioners of any information regarding their basis in the Calmin Drive property, the gain determined by respondent on the disposition of the property in 1992 is sustained. In the absence of presentation by petitioners of any information or documentation that they are entitled to deductions for the years 1992-95 inclusive, petitioners are not entitled to any deductions in computing their adjusted gross income or taxable income for those years. Petitioner Kenneth Anderson received unemployment compensation of $3,480 in 1992, and he is subject to self- employment taxes for 1992 and 1993. Finally, petitioners are liable for the accuracy-related penalty under section 6662(a) for each of the years 1992 through 1995. Issue 2. Section 6673 Penalty The Court, in its prior opinion in this case, decided to impose a penalty of $10,000 under section 6673 on the grounds ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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