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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.
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Last modified: May 25, 2011