Cliff Connors - Page 12

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               paid by the insurance company as provided by the                       
               insurance policy; he actually received a reduced amount                
               of funds in 2002 from his federal court case, and                      
               lawyers therein withheld most of said funds pending                    
               outcome of the other case on attorney fees for the                     
               federal court case; further, he did indeed pay premiums                
               for health and disability insurance coverage through                   
               his employer, Time Warner; and that, if any deficiency                 
               is sustained against him, then he is entitled to such                  
               exemptions, credits and deductions including earned                    
               income credit as allowed for a married man with three                  
               children and others that apply to his circumstances.                   
          There were no documents, records, or affidavits attached to the             
          offer of proof to substantiate any of the statements made                   
               Additionally, petitioner never sought to be relieved of the            
          deemed admissions in this case.  The deemed admissions include              
          that petitioner paid no premiums toward his insurance policy,               
          that Connecticut General’s 2002 payment of $269,474 to petitioner           
          was in satisfaction of the insurance company’s requirement to pay           
          to petitioner 66-2/3 percent of his salary as a disability                  
          payment, that the 2002 Form W-2 for $269,474 included no Federal            
          income tax withholding, that petitioner earned interest income of           
          $972 and $15 from Citibank in 2002 on the escrow account and a              
          U.S. savings bond, respectively, that petitioner’s failure to               
          file timely the 2002 tax return was not due to reasonable cause             
          and was due to willful neglect, and that the section 6651(a)(1)             
          and (2) additions to tax are applicable for 2002.                           
               Respondent objected to the motion to amend the petition and            
          to reopening the record.  By order dated June 27, 2006, the Court           

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