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.
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