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Memo. 1987-366, the Court denied petitioner's motion to vacate.
Petitioner did not file any notice of appeal in docket No.
37347-84. Accordingly, the Court's decision in that docket has
long been final. See secs. 7481(a)(1), 7483.
B. Taxable Year 1981
On August 19, 1988, respondent issued a notice of deficiency
to petitioner determining a deficiency of $205,662 in his Federal
income tax for 1981. Respondent also determined that petitioner
was liable for additions to tax for such year under section
6653(a)(1) and (2) for negligence or intentional disregard of
rules and regulations.
On November 16, 1988, petitioner filed a timely petition
with the Court (assigned docket No. 29751-88) contesting the
notice of deficiency for 1981. On July 20, 1989, the Court
entered an Order of Dismissal and Decision, sustaining
respondent's determinations for 1981 on the ground that
petitioner had failed to properly prosecute his case and had
failed to comply with a prior order of the Court. The Court
subsequently denied petitioner's Motion to Vacate its order of
dismissal.
Petitioner did not file any notice of appeal in docket No.
29751-88. Accordingly, the Court's decision in that docket has
long been final. See secs. 7481(a)(1), 7483.
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