The Nis Family Trust - Page 1

                                          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.                         

                        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-                          

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Last modified: May 25, 2011