Terri L. Steffen - Page 2

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                               Additions to tax                                       
                    Sec. 6653(a)(1)(A)   Sec. 6653(a)(1)(B)                           
                      $100,233        50% of the interest                             
                                        due on $2,004,465                             
          After concessions,2 the issue for decision is whether petitioner            
          is liable for additions to tax for negligence pursuant to section           
          6653(a)(1)(A)3 and (B) for the taxable year 1986.                           
               On September 11, 1998, respondent moved, pursuant to Rule              
          91(f), to compel petitioner to enter into a proposed stipulation            
          of facts.  We ordered petitioner to show cause why the matters              
          covered by respondent’s motion should not be deemed admitted for            
          purposes of this case.  Petitioner failed to respond to the order           
          to show cause.  We, therefore, granted respondent’s motion and              
          deemed the matters contained in the proposed stipulation to be              
          facts for purposes of this case.  Rule 91(f).                               
                                  FINDINGS OF FACT                                    
               Petitioner resided in Tampa, Florida, at the time she filed            
          her petition.  Petitioner and Paul A. Bilzerian (Mr. Bilzerian)             

          joint return for 1986.  Separate notices of deficiency were sent            
          to petitioner and Mr. Bilzerian, and separate petitions were                
          filed.  We addressed the liability of Mr. Bilzerian in a prior              
          opinion.  See Bilzerian v. Commissioner, T.C. Memo. 2001-187.               
          This Memorandum Opinion addresses the liability of petitioner.              
               2Petitioner concedes that she is not entitled to carry back            
          a worthless stock loss of $23,366,705 from 1989 to 1986.                    
               3Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              

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