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Sec. 6651(a)(1)1 Sec. 6662(a)
Year Deficiency Addition Penalty
1992 $95,829 $23,723 $18,978
1993 19,503 4,738 3,790
1994 4,939 237 189
1995 5,156 --- 1,031
Respondent has two motions pending before the Court: Under
Rule 121, respondent's motion for summary judgment on all issues
remaining unresolved in this case after the Court, in an opinion
filed in this case as Anderson v. Commissioner, T.C. Memo. 1998-
253, granted partial summary judgment for respondent on some
issues raised in respondent's prior motion for partial summary
judgment; and, under Rule 53, respondent's motion to dismiss for
lack of prosecution.
We shall grant respondent's motion for summary judgment,
rendering moot respondent's motion to dismiss. Sua sponte, we
shall require petitioners to pay a penalty of $1,000 under
section 6673, to be added to the $10,000 penalty already decided
in the Court's prior opinion in this case.
Background
We incorporate herein the background statement and
discussion set forth in the Court's prior opinion in this case at
T.C. Memo. 1998-253. In that opinion, the Court granted partial
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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