Michael T. Carey and Leone R. Carey - Page 2

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          6651(a) of $74,874.99, and an accuracy-related penalty under                
          section 6662(a) of $99,786.60.                                              
               As discussed below, we will grant respondent’s motion and              
          will impose a penalty against petitioners under section 6673 in             
          the amount of $5,000.                                                       
               Section references are to the Internal Revenue Code as                 
          amended, and Rule references are to the Tax Court Rules of                  
          Practice and Procedure.  References to petitioner are to Michael            
          T. Carey.                                                                   
                                     Background                                       
          A.   Petitioners                                                            
               Petitioners resided in Redding, California, when they filed            
          their petition.  Petitioner is a licensed occupational therapist.           
          He performed services at several adult residential facilities in            
          1997.                                                                       
          B.   Respondent’s Request for Admissions                                    
               Respondent sent a request for admissions to petitioners.               
          Petitioners did not respond to respondent's request for                     
          admissions.  Each statement in a request for admissions served on           
          a party is deemed admitted unless a response is served on the               
          requesting party within 30 days after service of the request.               
          Rule 90(c).  Thus, we deem petitioners to have admitted the                 
          following facts stated in respondent's request for admissions.              








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