- 7 -
reply, Mr. Wilson disputes certain of the facts on which respon-
dent relies in respondent’s motion.6 For example, Mr. Wilson
contends that any money that he received from Industrial Medical
represented loan repayments.7 We reject that contention. The
matters deemed established and deemed admitted in the instant
case establish, inter alia, that during 1993 and 1994 Industrial
Medical paid compensation to Mr. Wilson of $44,000 and $30,621,
respectively, and to Ms. Wilson of $7,315 and $15,030, respec-
tively, which they failed to include in their respective 1993 and
1994 joint returns. We also reject Mr. Wilson’s contention that
there are factual disputes with respect to other matters on which
respondent relies in respondent’s motion. That is because those
other matters have been deemed established and deemed admitted in
the instant case.8
In Mr. Wilson’s response as supplemented and Mr. Wilson’s
reply, Mr. Wilson also alleges certain facts upon which respon-
6Some of the facts on which respondent relies in respon-
dent’s motion and which Mr. Wilson disputes are not material to
resolving the issues raised in respondent’s motion. For example,
in Mr. Wilson’s supplement, Mr. Wilson asserts that he never
claimed to be a pharmacist and that he did not own or operate
Pleasantville.
7Respondent does not dispute that, in addition to the unre-
ported compensation of $30,621 that Mr. Wilson received from
Industrial Medical during 1994, Mr. Wilson received $98,934 in
loan repayments from Industrial Medical during that year.
8Moreover, as discussed below, the doctrine of collateral
estoppel precludes Mr. Wilson from litigating here matters
litigated in Mr. Wilson’s criminal tax proceeding.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011