- 2 - 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 9,606Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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