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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1986 $4,806 $1,202 $233
1987 3,294 824 177
1988 16,668 4,167 1,072
1989 15,040 3,760 1,017
1990 36,868 9,217 2,414
1991 35,951 8,988 2,055
1992 14,907 3,727 650
1993 9,485 2,371 397
On June 21, 1999, the Court granted without objection
respondent's oral motion to dismiss for failure to prosecute
properly. The sole remaining issue is respondent's Motion To
Impose Damages Under I.R.C. Section 6673.1 The Court grants
respondent's motion in that we require petitioner to pay a
penalty to the United States in the amount of $25,000.
We combine our findings of fact with our opinion.
Background
At the time the petition in this case was filed, petitioner
resided in Helena, Montana.
This case was originally set for trial on June 15, 1998. At
that time, petitioner was represented by counsel. On March 18,
1998, petitioner's counsel filed a motion to withdraw, which was
granted on April 14, 1998.
On March 13, 1998, counsel for respondent served on
petitioner Respondent's Request for Production of Documents and
1All section references are to the Internal Revenue Code in
effect for the taxable years in issue.
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