T.C. Memo. 2002-43
UNITED STATES TAX COURT
PATRICIA R. CARPENTIER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2430-96. Filed February 12, 2002.
Douglas D. Potratz, for petitioner.
Timothy F. Salel, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent moved for the dismissal of this
case for lack of petitioner’s prosecution. Respondent also moved
that a penalty be awarded to the United States under section
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