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$80,453.10 for 1995 and 6,617.30 for 1997.1 Currently, the case
is before the Court on respondent’s motion for summary judgment
under Rule 121 and to impose a penalty under section 6673(a).
Petitioners have filed with the Court a response to respondent’s
motion.2
We shall grant respondent’s motion for summary judgment and
shall impose a $2,500 penalty against petitioners. Unless
otherwise noted, section references are to the applicable
versions of the Internal Revenue Code. Rule references are to
the Tax Court Rules of Practice and Procedure.
Background
Petitioners filed Federal income tax returns for 1993, 1995,
and 1997, and respondent assessed the Federal income tax
liabilities shown on those returns. Respondent assessed the 1993
liability on May 16, 1994, the 1995 liability on March 10, 1997,
and the 1997 liability on December 28, 1998.
On November 7, 1999, respondent mailed to petitioners a
letter, “Final Notice - Notice of Intent to Levy and Notice of
1 We use the term “approximately” because these amounts were
computed before the present proceeding and have since increased
on account of interest.
2 As part of their response, petitioners challenge as
improper a declaration of respondent’s counsel that accompanied
respondent’s motion for summary judgment. The declaration
describes certain documents contained in respondent’s
administrative file, all of which were submitted to the Court as
part of respondent’s motion for summary judgment. We find
petitioners’ challenge disingenuous.
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