- 3 -
Crystal D. Sluyter, for petitioners.
Dale A. Zusi, Paul K. Webb, and Debra K. Moe, for
respondent.
OPINION
HALPERN, Judge: These cases have been consolidated for
trial, briefing, and opinion (the consolidated cases or these
cases). Respondent has determined deficiencies in income tax and
accuracy-related penalties under section 6662 as follows:
Taxable
Petitioner[s] Year Deficiency Penalty
The Nis Family Trust,
Frank Ni, Trustee 1995 $83 $17
Nis Venture Trust,
Frank Ni, Trustee 1995 172,702 34,540
Hae-Rong and
Lucy B. Ni 1995 186,988 37,398
These cases are before the Court on (1) respondent’s motions for
(A) judgment on the pleadings and (B) partial summary judgment
and (2) the Court’s orders to show cause why it should not impose
(A) penalties on petitioners pursuant to section 6673(a)(1) and
(B) require counsel for petitioners, Crystal D. Sluyter, to pay
costs, expenses, and fees (without distinction, costs) pursuant
to section 6673(a)(2).
Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the year in issue, and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011