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the income tax deficiency and penalty determined in the notice of
deficiency because this case contains no genuine issue as to any
material fact and that judgment should be rendered as a matter of
law.
Background
Respondent determined a deficiency in petitioner's Federal
income tax for taxable year 1991 in the amount of $29,027.
Respondent further determined that petitioner is liable for the
accuracy-related penalty under section 6662(a) in the amount of
$5,805. A notice of deficiency was issued on March 17, 1995.
On September 27, 1996, petitioner filed a motion for
continuance (petitioner's motion), requesting that this case be
continued due to a surgical operation performed on her knee.
According to her motion, petitioner's physical condition
following said surgical operation prevented her from traveling to
Tampa, Florida, for the trial in this case. On September 30,
1996, before the Court had ruled on petitioner's motion, this
case was called for trial at Tampa, Florida. Neither petitioner
nor anyone acting on her behalf made an appearance. Counsel for
respondent, however, appeared and was heard. Despite
petitioner's absence at the calender call, the Court considered
and granted her motion for continuance.
On November 13, 1996, respondent filed her above-referenced
motion for summary judgment (respondent's motion). On November
15, 1996, the Court ordered (the Court's order) petitioner to
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