Robert Emmett Robertson, III - Page 7




                                        - 7 -                                         
          receipts was actually interest income; the parties seem to read             
          the stipulation as to the 1982 item the same way.  We conclude              
          that justice does not require us to relieve petitioner from the             
          effect of the parties’ stipulations.  See Rule 91(e), Tax Court             
          Rules of Practice and Procedure; Louisiana Land & Exploration Co.           
          v. Commissioner, 90 T.C. 630, 648 (1988).                                   
                            _____________________________                             
               Time after time petitioner has interposed objections or new            
          considerations which have had the effect of delaying resolution             
          of the instant case and only rarely have affected the decision to           
          be entered.  Petitioner stated that the matters dealt with in               
          this opinion were raised after discussion with an unnamed tax               
          adviser.  Notwithstanding petitioner’s frequent protestations               
          about his inability to understand the tax laws and our agreement            
          with him that much of the Internal Revenue Code would challenge             
          an Einstein, we are satisfied from our observations of petitioner           
          that he has a reasonably good understanding of the essentials of            
          those Code provisions that apply to him.  Under these                       
          circumstances, if petitioner proceeds in a like manner in a                 
          future case, he should understand that the Court may be inclined            
          to give serious consideration to imposition of a penalty under              
          section 6673.  Petitioner may not be then able to hide behind the           
          asserted advice of his unnamed tax adviser.                                 








Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011