- 2 - we conclude that no issues of material fact that require trial remain. For the reasons stated below, we shall grant respondent’s motion for summary judgment. Background At the time of filing the petition, petitioner resided in Gastonia, North Carolina. Petitioner failed to file Federal income tax returns or pay taxes for taxable years 1999, 2000, and 2002. During each of the years in issue, petitioner had income in the form of wages, dividends, capital gains, interest, and nonemployee compensation. On September 28, 2004, respondent issued separate notices of deficiency to petitioner for the 1999, 2000, and 2002 taxable years. The notices determined the deficiency for each year, plus section 6651(a)(1) and section 6654(a) additions to tax. Petitioner timely petitioned this Court for redetermination of the deficiencies. Respondent timely filed an answer. At the call of the calendar for the instant case on May 22, 2006, the Court ruled that respondent’s proposed Stipulation of Facts was deemed established pursuant to respondent’s Rule 91(f) motion. The instant case was continued, and on June 21, 2006, respondent moved for summary judgment. Petitioner timely filed a response but failed to state any specific facts that show the existence of a genuine question of material fact.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011