- 4 - all Rule references are to the Tax Court Rules of Practice and Procedure. Background Residence At the time the petitions were filed, all petitioners resided in San Jose, California. Notices of Deficiency By separate notices of deficiency, each dated February 19, 1999 (collectively, the notices of deficiency or notices), respondent determined the deficiencies in tax and penalties set forth above.2 Respondent’s determinations were based on the following adjustments: Nis Family Trust Respondent disallowed petitioner’s deduction for fiduciary and attorney’s fees in the amount of $600 because of petitioner’s failure to establish the amount, if any, of such fees paid during the taxable year for ordinary and necessary expenses incurred in connection with trust administration or the management of trust assets. Respondent disallowed petitioner’s deduction for a charitable contribution in the amount of $1,800 because of 2 Copies of those notices of deficiency are attached as Exhibits A through C to respondent’s requests for admissions. As set forth below, petitioners failed timely to deny respondent’s requests for admissions, and, therefore, such requests are deemed admitted. See Rule 90. Petitioners are also deemed to admit that petitioner Hae-Rong Ni is also known as Frank Ni.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011