Larry Brown - Page 2

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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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