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deductions from that income, except to the very limited extent
described below.
Notwithstanding these conclusions, we deny respondent’s
motion for a penalty under section 6673. We also deny
respondent’s motion (and other requests) for the exclusion of
evidence (or other relief) as a sanction for petitioner’s
conduct.
Procedural Setting
The statutory notice sent to petitioner determined that
petitioner had failed to report $104,786 in business gross
receipts. Respondent also sent notices to Julia Ghavami (Ms.
Ghavami) and to Universal for 1993, reflecting determinations
that Ms. Ghavami and Universal had each received an identical
amount (i.e., $104,786) of business gross receipts. As explained
in more detail below, these notices were “whipsaw” notices,
designed to protect respondent’s position if it should be decided
that Universal had economic substance and should be respected as
a separate taxable entity.
Ms. Ghavami filed a petition with this Court contesting
respondent’s determination for 1993. See Julia Ghavami v.
Commissioner, docket No. 3692-99 (Ghavami). Jimmy C. Chisum (Mr.
Chisum)2, as “Managing Agent for Trustee”, purported to file a
2 We note that Mr. Chisum, and a myriad of purported
“trusts” with which he has claimed to be connected, are well
(continued...)
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