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60(a).2 The petition was filed with the Court in the name of
petitioner by Mr. Jablonski, in his stated capacity as
petitioner’s managing director. Petitioner is purportedly an
irrevocable trust, the settlor of which is Mr. Jablonski.
Petitioner petitioned the Court to redetermine respondent’s
determination of deficiencies of $126,279 and $25,265 in its
Federal income tax for 1995 and 1996, respectively, and accuracy-
related penalties under section 6662(a) of $25,255.80 and $5,053,
respectively.
On June 27, 2000, we ordered petitioner to respond to
respondent’s motion by July 11, 2000, setting forth in its
response its position as to the motion and attaching any
pertinent documents in support of its position. We ordered
petitioner to list in its response the name of its trustee and a
list of its assets and liabilities as of the date of the
response. We ordered petitioner to attach to its response a copy
of the trust instrument(s) under which it has operated on or
after the date of the petition. We admonished petitioner that we
might dismiss its case if it did not comply fully with our order.
On July 17, 2000, petitioner filed its response with the
Court. The response attached a copy of a trust instrument for
2 Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code
in effect for the years in issue.
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