- 2 - 60(a).2 The petition was filed with the Court in the name of petitioner by its cosettlor, Mr. Jablonski, in his stated capacity as petitioner’s managing director.3 Petitioner petitioned the Court to redetermine respondent’s determination of deficiencies of $1,417,739 and $1,271,047 in its Federal income tax for 1994 and 1995, respectively, and accuracy-related penalties under section 6662(a) of $283,547.80 and $254,209.40, 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. 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. 3 The other cosettlor is Marsha Jablonski. The trust instrument defines a settlor as “That person who is settling or exchanging his property into the Trust Organization.”Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011