James S. Zigmont - Page 4

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               (1) Petitioner received Social Security payments of $10,758            
          and $12,180 in 2000 and 2001, respectively;                                 
               (2) petitioner received the proceeds of stock and bond sales           
          totaling $490,268 and $234,728 in 2000 and 2001, respectively;              
               (3) petitioner did not submit to respondent information                
          regarding the cost of the stocks and bonds sold in 2000 and 2001;           
               (4) petitioner received payments from an IRA or other                  
          retirement plan of $13,933 in 2000 and 2001;                                
               (5) petitioner received dividends on stock of $188 and $29             
          in 2000 and 2001, respectively;                                             
               (6) petitioner earned interest of $17,228 and $28,296 in               
          2000 and 2001, respectively;                                                
               (7) petitioner failed to file Federal income tax returns for           
          2000 and 2001; and                                                          
               (8) petitioner did not make the required payments of                   
          estimated taxes for 2000 or 2001, through withheld taxes or                 
          otherwise.                                                                  
               Respondent then filed a motion for summary judgment on                 
          September 26, 2005.  Petitioner did not file timely a response to           
          respondent’s motion.  However, on October 25, 2005, petitioner              
          filed a motion to withdraw deemed admissions, lodged petitioner’s           
          responses to respondent’s requests for admission, and filed a               
          Rule 50(c) statement in response to respondent’s motion for                 
          summary judgment.  Petitioner’s motion to withdraw deemed                   






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