T.C. Memo. 2002-240
UNITED STATES TAX COURT
JOHN THURMAN & ELAINE SHERYL HOREJS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8928-01L. Filed September 25, 2002.
John Thurman & Elaine Sheryl Horejs, pro sese.
Anne W. Durning and Sheara L. Gelman, 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, as amended, filed
pursuant to Rule 121.1 Respondent contends that there is no
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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