Marcus C. Seay - Page 2

                                        - 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.                                   
               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