Kenneth E. Bixler - Page 2

          and adopts the Opinion of the Special Trial Judge, which is set             
          forth below.                                                                
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               ARMEN, Special Trial Judge:  This case is before the Court             
          on (1) Respondent's Motion To Dismiss For Failure To Properly               
          Prosecute; (2) respondent's Motion To Impose Sanctions For                  
          Petitioner's Failure To Comply With Order Directing Production Of           
          Documents; (3) respondent's Motion To Impose Sanctions Pursuant             
          To I.R.C. � 6673; and (4) petitioner's Motion To Dismiss, as                
          supplemented.                                                               
               Petitioner resided in Warsaw, Indiana, at the time that the            
          petition was filed in this case.                                            
               We begin by setting forth the background necessary to an               
          understanding of the parties' four motions.                                 
          Respondent's Notice of Deficiency                                           
               Respondent issued a notice of deficiency to petitioner dated           
          April 19, 1995, that determined the following deficiency in                 
          petitioner's Federal income tax and additions to tax:                       
                   Additions to tax                                                   
          Year     Deficiency     Sec. 6651(a)(1)     Sec. 6654(a)                    
          1992     $9,474            $1,251.25           $196.36                      

               The deficiency in income tax, which includes self-employment           
          tax in the amount of $216, is based on respondent's determination           
          that petitioner failed to report the following items of income:             








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