- 7 - petitioner’s testimony and his denial of fraudulent intent. Petitioner acknowledged that he continued failing to file tax returns until the eve of trial of this case. The thrust of his testimony is that petitioner and others pursued their course of tax protest as long as they could get away with it. See Niedringhaus v. Commissioner, 99 T.C. 202, 218-219 (1992). On consideration of the facts deemed admitted and petitioner’s testimony in opposition to the motion for summary judgment, we conclude that there is no genuine issue as to any material fact and that a decision may be rendered as a matter of law. Respondent’s motion for summary judgment, as modified in the stipulation of settled issues, will be granted. An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011