115 T.C. No. 37 UNITED STATES TAX COURT THE NIS FAMILY TRUST, FRANK NI, TRUSTEE, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9820-99, 9821-99, Filed December 4, 2000. 9822-99. The cases are before the Court on R’s motions for judgment on the pleadings and partial summary judgment and on the Court’s orders to show cause why it should not (1) impose penalties on Ps for instituting or maintaining proceedings primarily for delay or for advancing frivolous or groundless positions, and (2) require Ps’ attorney, S, to pay excess costs, expenses, and fees for her bad faith course of conduct by which she unreasonably and vexatiously multiplied these proceedings. In the petitions, Ps fail to address any of the adjustments made in the notices of deficiency, raising 1 Cases of the following petitioners are consolidated herewith: Nis Venture Trust, Frank [Hae-Rong] Ni, Trustee, docket No. 9821-99, and Hae-Rong and Lucy B. Ni, docket No. 9822- 99.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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