- 7 - “deemed admitted admissions” and accept petitioner’s answers to respondent’s admissions. On October 16, 2000, considering petitioner’s presence at trial, the Court denied respondent’s motion to dismiss and for the imposition of a section 6673 penalty. Although the case was allowed to continue, the Court denied petitioner’s motion to withdraw the deemed admissions. At trial on October 16, 2000, the Court consolidated petitioner’s case with the trust’s case. After a considerable exchange regarding his oath, petitioner testified (in general) that “I think I filed everything I needed to, that I was required to.” Petitioner's Income-Producing Activity During 1994, 1995, 1996, and 1997, petitioner performed computer analysis and programming services for Duraflame, Inc., and California Cedar Products, Inc. These companies paid for petitioner’s services at an hourly rate and made payments directly to the trust. Petitioner did not file individual Federal income tax returns for 1994 through 1997. Forms 1041, U.S. Income Tax Return for Estates and Trusts, were filed on behalf of the trust for 1994, 1995, 1996, and 1997. Respondent made the following alternative determinations with regard to the trust: (1) The trust is not entitled to various deductions and exemptions; (2) it is a sham; and (3) it is a grantor trust subject to sections 671 through 679. Respondent also determined that the money paidPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011