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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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