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Thomas Gerald Roots and Linda Vesta Roots, pro se.
Mark A. Weiner, for respondent.
MEMORANDUM OPINION
CHABOT, Judge: This matter is before us on petitioners'
motion to dismiss for lack of jurisdiction. As indicated infra,
we also consider whether petitioners are entitled to summary
judgment.
We decide these matters on the basis of the parties'
pleadings and motion papers.
Respondent determined a deficiency in Federal income tax and
additions to tax under sections 6651(a)(1)1 (failure to timely
file tax return) and 6662(a) (negligence, etc.) against
petitioners as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $121,483 $30,371 $24,296
Background
When the petition was filed in the instant case, petitioners
resided in Ventura, California.
Petitioners filed their 1991 tax return on March 27, 1993.
A Form 872, extending to December 31, 1996, the time to assess
1 Unless indicated otherwise, all section references are
to sections of the Internal Revenue Code of 1986, as in effect
for the year in issue.
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