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summary judgment for respondent on the basis of deemed admissions
by petitioners on the issues of wage income and liability for
additions to tax under section 6651(a) for unexcused late filing
of their returns. The Court also decided that a $10,000 penalty
would be imposed on petitioners under section 6673 for advancing
frivolous and groundless contentions. However, the Court
concluded that it would not be appropriate on the then existing
record to grant summary judgment in favor of respondent on the
self-employment tax issue for 1992-93 and the gain from the sale
of real estate and commissions and expenses on the sale. Other
issues raised in the statutory notices of deficiency that were
not covered by the original motion for summary judgment were
whether petitioners received taxable unemployment compensation of
$3,480 during 1992, whether petitioners had $275,000 of
cancellation of indebtedness income in connection with the sale
of real estate, and the accuracy-related penalties and deductions
for 1992-95.
On December 31, 1998, following issuance of the order
pursuant to the Court's prior opinion in this case, the Court
served on the parties its notice setting this case for trial at
the Court's San Diego, California, trial session scheduled to
begin June 7, 1999.
On March 22, 1999, the Court received Respondent’s Third
Request for Admissions, attached to which was a Certificate of
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