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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