- 10 - As directed by the Court, petitioner filed a response to respondent’s motion. That response stated: This letter is in response to the motion filed for summary judgment. I would respectfully ask that this judgment not be granted to the respondent. As I am currently in the process of addressing all the concerns and the requested documents asked by the respondent. [Reproduced literally.] Petitioner filed petitioner’s response to respondent’s motion over six months ago. The Court has given petitioner ample time to establish his claim that respondent’s motion should not be granted. He has failed to do so.3 Based upon our examination of the entire record before us, we conclude that petitioner has failed to show that there are genuine issues of material fact regarding the questions raised in respondent’s motion. On that record, we find that petitioner has failed to show error in the determinations that respondent made in the notice of deficiency that respondent issued to him for his taxable year 1998. On the record before us, we find that the determinations in the notice of determination with respect to petitioner’s taxable year 1998 should be sustained. On that 3The petition that petitioner filed in this case also is unhelpful to petitioner’s position. The only issue that petitioner appears to raise in the petition in this case is the underlying tax liability for his taxable year 1998. However, petitioner fails to allege any specific error in the petition relating to the determinations that respondent made in the notice of deficiency that respondent issued to him with respect to that year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007