- 2 - filed with the Court by a proper party as required by Rule 60(a).2 The petition was filed with the Court in the name of petitioner by Mr. Jablonski, in his stated capacity as petitioner’s trustee. Petitioner petitioned the Court to redetermine respondent’s determination of deficiencies of $323,810 and $245,822 in its Federal income tax for 1995 and 1996, respectively, accuracy-related penalties under section 6662(a) of $64,762 and $49,164.40, respectively, and a $64,762 addition to tax for 1995 under section 6651(a). On June 27, 2000, we ordered petitioner to respond to respondent’s motion by July 11, 2000, setting forth in its response its position as to the motion and attaching any pertinent documents in support of its position. We ordered petitioner to list in its response the name of its trustee and a list of its assets and liabilities as of the date of the response. We ordered petitioner to attach to its response a copy of the trust instrument(s) under which it has operated on or after the date of the petition. We admonished petitioner that we might dismiss its case if it did not comply fully with our order. On July 17, 2000, petitioner filed its response with the Court. The response attached a copy of a trust instrument for 2 Rule references are to the Tax Court Rules of Practice and Procedure. Section references are to the Internal Revenue Code in effect for the years in issue.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011