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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1997 $55,151 $12,388 $2,971
1998 25,421 5,720 1,154
2000 11,687 838 --
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Background
Under Rule 91(f)(3), some of the facts have been deemed
stipulated and are so found.1
At the time the petition was filed, petitioner was a
resident of Edgefield, South Carolina.
For 1996, a year not in issue, petitioner filed his 1996
individual Federal income tax return and indicated thereon a
1 On July 9, 2004, respondent filed a Motion To Show Cause
Why Proposed Facts In Evidence Should Not Be Accepted As
Established (Rule 91(f) motion). On July 27, 2004, the Court
issued an order granting respondent’s Rule 91(f) motion and
directing petitioner to file a response to the motion by Aug. 27,
2004. The July 27, 2004, order also explained that failure by
petitioner to respond to any matter set forth in respondent’s
Rule 91(f) motion, including the proposed stipulation of facts,
would result in such matter’s being deemed stipulated for
purposes of the instant case. Petitioner failed to respond to
respondent’s Rule 91(f) motion, and, on Sept. 8, 2004, the Court
made absolute its July 27, 2004, order, and the facts set forth
in the proposed stipulation of facts were deemed stipulated for
purposes of trial and opinion herein.
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