- 4 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011