-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.
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