- 2 -
Additions to tax
Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)
$100,233 50% of the interest
due on $2,004,465
After concessions,2 the issue for decision is whether petitioner
is liable for additions to tax for negligence pursuant to section
6653(a)(1)(A)3 and (B) for the taxable year 1986.
On September 11, 1998, respondent moved, pursuant to Rule
91(f), to compel petitioner to enter into a proposed stipulation
of facts. We ordered petitioner to show cause why the matters
covered by respondent’s motion should not be deemed admitted for
purposes of this case. Petitioner failed to respond to the order
to show cause. We, therefore, granted respondent’s motion and
deemed the matters contained in the proposed stipulation to be
facts for purposes of this case. Rule 91(f).
FINDINGS OF FACT
Petitioner resided in Tampa, Florida, at the time he filed
his petition.
Petitioner graduated from Stanford University. After
graduating from Stanford, he attended Harvard University and
graduated in 1977 with a master’s degree in business
2Petitioner concedes that he is not entitled to carry back a
worthless stock loss of $23,366,705 from 1989 to 1986.
3Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011