Lou Deserio - Page 6

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          attack the merits of respondent’s determination and has refused             
          and/or failed to prepare and present any such arguments to this             
          Respondent’s Motion To Dismiss for Lack of Prosecution                      
               Respondent has moved to dismiss this case due to                       
          petitioner’s lack of prosecution and for this Court to enter a              
          decision that petitioner is liable for deficiencies in and                  
          additions to Federal income tax in the full amounts set forth in            
          the notices of deficiency for 1992, 1993, and 1994 and in reduced           
          amounts for 1995 and 1996.  Petitioner does not allege that                 
          respondent’s allegations in support of his motions are incorrect.           
          In response to respondent’s motions and this Court’s order to               
          show cause, petitioner merely counters that this Court and                  
          respondent are without authority to determine or decide any                 
          income tax deficiencies regarding certain entities (trusts and a            
          limited liability corporation).                                             
               Petitioner has not complied with this Court’s pretrial order           
          that required his preparation of this case for trial, including             
          the exchange of information and stipulation of facts.  Petitioner           
          has not cooperated with respondent’s efforts to comply with this            
          Court’s Rules.  Petitioner did not appear for trial or otherwise            
          offer evidence that would show that respondent’s determination is           
          in error.  Respondent has not been shown to bear the burden with            
          respect to any of the adjustments or determinations contained in            

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