All Community Walk In Clinic - Page 3

                                          -3-                                         
          additions to tax for negligence and delinquency.  The adjustments           
          in the notices of deficiency reflected primarily respondent’s               
          determinations that petitioners had understated income and                  
          overstated deductions.  Many of the issues in the two cases are             
          intrinsically related.                                                      
               On April 29, 1998, the Gazis and All Community Walk In                 
          Clinic filed petitions in this Court, challenging respondent’s              
          determinations in the notices of deficiency.  The petitions were            
          signed by Mr. Kauffman, who is an attorney authorized to practice           
          before this Court.  On June 30 and July 2, 1998, respondent filed           
          answers in these cases.  The cases were set for trial at the                
          session of the Court beginning April 26, 1999, in Tampa, Florida.           
               On February 11, 1999, pursuant to Rule 90, respondent filed            
          requests for admission in the Gazis’ case (docket No. 7950-98).4            
          In the 133 numbered items in respondent’s requests for admission,           
          respondent requested the Gazis to admit the various elements of             
          the adjustments to taxable income reflected in the Gazis’ notice            
          of deficiency.  No response to respondent’s request for                     
          admissions was filed by or on behalf of the Gazis.  Consequently,           
          pursuant to Rule 90(c), each matter set forth in respondent’s               
          requested admissions was deemed admitted.                                   



               4 Unless otherwise indicated, Rule references are to the Tax           
          Court Rules of Practice and Procedure and section references are            
          to the Internal Revenue Code, as amended.                                   





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011