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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.
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Last modified: May 25, 2011