T.C. Memo. 2002-194
UNITED STATES TAX COURT
WILLIE R. DAVIDSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13540-01L. Filed August 7, 2002.
Willie R. Davidson, pro se.
Wendy S. Harris and Scott Hovey, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s Motion For Summary Judgment And To
Impose A Penalty Under I.R.C. Section 6673, filed pursuant to
Rule 121.1 Respondent contends that there is no dispute as to
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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