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By statutory notice of deficiency, respondent determined
deficiencies in and additions to petitioners' Federal income tax
in the following amounts:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6654 6661 6662(a)
1988 $15,063 $753.15 -- $3,765.75 --
1989 12,270 -- $182.56 -- $2,454
All section references are to the Internal Revenue Code in
effect for the years in issue, and Rule references are to the Tax
Court Rules of Practice and Procedure, unless otherwise
indicated.
The sole issue for decision is whether respondent's motion
to dismiss for failure to properly prosecute should be granted.
We hold that it should.
Background
Petitioners filed joint Federal income tax returns for the
years at issue. In response to the statutory notice, peti-
tioners, by and through their counsel, Todd M. Conover, timely
filed their petition on January 4, 1993. Petitioners resided in
Highland, Indiana, at the time the petition in this case was
filed.
Respondent's answer was filed on February 24, 1993. There-
after, this case was set for trial on January 31, 1994, in
Chicago, Illinois. Before the scheduled trial, petitioners'
counsel, Todd M. Conover, filed, on November 4, 1993, a motion to
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