- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011