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merits of those motions. This case was scheduled for trial at
the Court’s Phoenix, Arizona, trial session beginning January 29,
2001. Petitioner failed to appear, and respondent filed the
above-referenced motions. The Court, by an order dated January
29, 2001, directed petitioner to show cause, if any, why
respondent’s motions should not be granted.
Respondent determined that petitioner has deficiencies in
and additions to Federal income tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $58,789 $14,697 $2,564
1993 100,681 25,170 4,218
1994 127,233 31,808 6,602
19951 2,438 609 134
19962 1,810 362 95
1 The deficiency and additions to tax amounts at issue
differ from the amounts in the Notices of Deficiency dated Sept.
23, 1998, pursuant to the Court’s order dated Feb. 11, 2000.
2 See supra note 1.
Background
In support of his motions, respondent explains that on
several occasions petitioner was invited to stipulate the facts
in compliance with this Court’s Rules and pretrial order;
however, petitioner was unresponsive. Although petitioner
answered respondent’s request for admissions, he failed to
respond to interrogatories or requests for the production of
1(...continued)
indicated.
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