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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
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 in
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Last modified: May 25, 2011