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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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