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Rowlee v. Commissioner, 80 T.C. 1111 (1983). This Court denied
the motion on November 22, 1988.
On February 23, 1989, this Court dismissed petitioners' case
at docket No. 5010-88, for lack of prosecution due to their
failure to appear at a February 13, 1989, calendar call at
Muskogee, Oklahoma. The Court entered a decision that, for the
year 1984, petitioners owed an income tax deficiency of $212,697,
with additions to tax under sections 6653(a)(1) and 6661 of
$10,635 and $53,174, respectively, and under section 6653(a)(2)
of 50 percent of the interest due on the deficiency.
On May 14, 1990, respondent offered petitioners the
opportunity to be bound by the outcome of the then pending case
of Gampp v. Commissioner, docket No. 16968-87, as to the Petro
West issue. In this letter, respondent cautioned petitioners
that the Government would seek an award of damages pursuant to
section 6673 if they continued to pursue their frivolous
protester arguments. Petitioners did not respond to this
correspondence.
By letters dated June 23, 1994, August 18, 1994, August 24,
1994, and August 29, 1994, respondent attempted to enlist
petitioners' assistance in preparing this case for trial.
Forwarded with this correspondence were copies of Rule 70(a)(1),
Rule 91(a), Order dated August 2, 1994, with attached Standing
Pre-Trial Order, Stipulated Decision Document, Gampp v.
Commissioner, T.C. Memo. 1991-548.
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