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(4) Petitioner did not report the income he received from
the operation of Liberty Temp on his 2002 return;
(5) Because petitioner did not report the income received
from the operation of Liberty Temp on his 2002 return, he
underpaid the tax required to be shown on that return;
(6) The underpayment of tax required to be shown was
attributable to fraud;
(7) Petitioner unreasonably failed to pursue available
administrative remedies with respondent; and
(8) Respondent requested an informal interview with
petitioner, but petitioner refused.
At no point did petitioner move to withdraw or modify the
deemed admissions.
To reflect the deemed admissions, respondent filed an
amendment to answer asserting that petitioner was liable for a
fraud penalty under section 6663(a) in the alternative to the
accuracy-related penalty under section 6662(a) asserted in the
notice of deficiency. Respondent also filed a motion to impose a
penalty under section 6673(a)(1)(C) for petitioner’s unreasonable
failure to pursue available administrative remedies.
On March 13, 2006, the day of calendar call, petitioner
filed a motion to continue. Petitioner’s motion was denied.
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