T.C. Memo. 1996-319
UNITED STATES TAX COURT
SCOTT R. PHILIPS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5057-96. Filed July 15, 1996.
Scott R. Philips, pro se.
Michael H. Salama, for respondent.
MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(4)1 and Rules 180, 181, and
183. This case is before us on respondent's Motion to Dismiss
for Failure to State A Claim and to Impose a Penalty Under
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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