T.C. Memo. 1996-328 UNITED STATES TAX COURT VIVIAN D. RODRIGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 561-96. Filed July 18, 1996. Vivian D. Rodriguez, pro se. Lynda B. Taylor, for respondent. MEMORANDUM OPINION NAMEROFF, Special Trial Judge: This case is before the Court on respondent's Motion to Dismiss For Failure to State a Claim And To Impose A Penalty Under I.R.C. Section 6673,1 filed pursuant to Rule 40. This case was assigned pursuant to section 1 All section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 Next
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