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2. Held, further, R's motion to impose sanctions
granted; this case will be dismissed; and decision will
be entered against P for deficiencies and accuracy-
related penalties under sec. 6662(a), I.R.C., in the
amounts determined by R for the taxable years 1992 and
1993. Rule 104(c)(3), Tax Court Rules of Practice and
Procedure.
Larry Brown, pro se.
William J. Gregg, for respondent.
MEMORANDUM OPINION
NIMS, Judge: This matter is before the Court on (1)
respondent's motion for partial summary judgment under Rule 121;
and (2) respondent's motion to impose sanctions under Rule
104(c), including dismissal of this case.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Respondent determined the following deficiencies and
accuracy-related penalties with respect to the Federal income tax
of Larry Brown (petitioner) and Elizabeth R. Brown (Elizabeth)
for the taxable years 1992 and 1993:
Penalties
Year Deficiency Sec. 6662(a)
1992 $89,372 $17,874
1993 48,028 9,606
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