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and Mr. Wilson filed a reply (Mr. Wilson’s reply) to respondent’s
reply.1 We shall grant respondent’s motion.
Background
All of the facts on which respondent relies in respondent’s
motion have been deemed established pursuant to the Court’s Order
under Rule 91(f)2 dated September 24, 2001, and pursuant to Rule
90(c).
At the time the petition in this case was filed, Mr. Wilson
resided in Goldsboro, North Carolina, and Ms. Wilson resided in
Myrtle Beach, South Carolina.
During 1993 and 1994, Mr. Wilson operated Pleasantville
Medical Services (Pleasantville) as a pharmacy. Pleasantville
was located in Baltimore, Maryland, within the operating location
of DK Medical Services, Inc., d/b/a Industrial Medical and
Physical Therapy (Industrial Medical). Deborah Kolodner, Mr.
Wilson’s daughter, owned and operated Industrial Medical.
1Petitioner Dorris E. Wilson (Ms. Wilson) did not sign Mr.
Wilson’s response, Mr. Wilson’s supplement to that response, or
Mr. Wilson’s reply. There is no indication in the record that
Ms. Wilson authorized Mr. Wilson to speak on her behalf in those
filings. We conclude that Ms. Wilson does not dispute that
respondent’s motion should be granted as to her. Assuming
arguendo that we had not concluded that Ms. Wilson does not
dispute that respondent’s motion should be granted as to her, on
the record before us, we conclude that respondent’s motion should
be granted as to Ms. Wilson.
2All Rule references are to the Tax Court Rules of Practice
and Procedure. Unless otherwise indicated, all section refer-
ences are to the Internal Revenue Code in effect for the years at
issue.
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Last modified: May 25, 2011