T.C. Memo. 2003-117
UNITED STATES TAX COURT
RAYMOND BOURBEAU, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6898-02L. Filed April 22, 2003.
Raymond Bourbeau, pro se.
D. Sean McMahon, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for summary judgment and to impose a penalty
under I.R.C. section 66731 (motion for summary judgment).
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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