- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011