- 2 -
Year Deficiency Accuracy-Related Penalty
1994 $12,258 $2,451
1995 14,219 2,843
We must decide whether the determinations in the notice of
deficiency (notice) for each of the years at issue that have not
been conceded by respondent should be sustained. We hold that
they should.
Some of the facts have been stipulated and are so found. On
November 9, 1998, respondent filed a request for admissions with
the Court, a copy of which respondent had served on petitioner on
November 4, 1998. Petitioner did not file any response to that
request. As a result, each matter set forth in respondent's
request for admissions is deemed admitted. See Rule 90(c);
Marshall v. Commissioner, 85 T.C. 267, 272 (1985).
Petitioner resided in Lake Forest, California, at the time
he filed the petition.
During the years at issue, petitioner was self-employed as a
building contractor. Petitioner filed Form 1040, U.S. Individual
Income Tax Return, for each of the years 1994 and 1995. Peti-
tioner reported certain income and claimed certain expenses from
his activities as a building contractor in Schedule C of Form
1040 (Schedule C) for each of those years.
In the notice issued to petitioner, respondent made adjust-
ments to certain items of income and expense that petitioner
Page: Previous 1 2 3 Next
Last modified: May 25, 2011