- 6 - attack the merits of respondent’s determination and has refused and/or failed to prepare and present any such arguments to this Court. 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 inPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011