Scott R. Philips - Page 1

                                 T.C. Memo. 1996-319                                  

                               UNITED STATES TAX COURT                                

                           SCOTT R. PHILIPS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5057-96.                     Filed July 15, 1996.           

               Scott R. Philips, pro se.                                              

               Michael H. Salama, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(4)1 and Rules 180, 181, and           
          183.  This case is before us on respondent's Motion to Dismiss              
          for Failure to State A Claim and to Impose a Penalty Under                  

          1  All section references are to the Internal Revenue Code                  
          in effect for the years at issue.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  

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