Perry D. McBroom, Deceased, and Jackie S. McBroom - Page 4

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            sections 6653(a)(1) and (2) and 6659, and the increased interest                          
            under section 6621(c).  Respondent further concedes the increased                         
            deficiency and additions to tax asserted in her amended answer.                           
            The motion was calendared for hearing at the special session.                             
                  On September 19, 1994, Joel Drum, the sole remaining counsel                        
            for petitioners, filed a Motion to Withdraw, which was granted.                           
            At the special session on October 26, 1994, there was no                                  
            appearance by or on behalf of petitioner.  Subsequently, Michael                          
            A. Bickford filed his entry of appearance on behalf of petitioner                         
            on January 31, 1995.  To date, petitioner has not contested                               
            respondent's Motion for Summary Judgment.                                                 
                  On April 28, 1995, respondent filed a motion to dismiss,                            
            insofar as it pertains to petitioner Perry D. McBroom, for lack                           
            of prosecution.  As grounds in support of the motion, respondent                          
            alleges that respondent was advised by petitioner that all                                
            property belonging to Mr. McBroom passed on to her as his                                 
            surviving spouse, and, as a result, no estate was created and no                          
            personal representative was appointed.  On May 1, 1995, the Court                         
            received notice from petitioner's counsel that petitioner would                           
            "not be filing any further papers or requests of the Court at                             
            this time dealing with" the case.                                                         
                  In a supplemental motion to dismiss filed August 28, 1995,                          
            respondent requested that we find a deficiency in income tax for                          
            the taxable year 1982 due from Perry D. McBroom, deceased, in the                         
            amount of $8,288.  Respondent also conceded all additions to tax                          




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