Dennis M. Mudd - Page 3




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          most favorable to the party opposing summary judgment.  Dahlstrom           
          v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.                        
          Commissioner, 79 T.C. 340, 344 (1982).                                      
               As explained in detail below, there is no genuine issue as             
          to any material fact, and a decision may be rendered as a matter            
          of law.  Accordingly, we shall grant respondent’s motion for                
          summary judgment.                                                           
          Background                                                                  
               Petitioner and his wife, Sheila Mudd, filed joint Forms                
          1040, U.S. Individual Income Tax Return, for the taxable years              
          1992 to 1997 and 1999.  For each of these years, the Mudds                  
          reported taxable income, partially offset by credits for                    
          withholding taxes, leaving relatively modest amounts of taxes               
          due.  However, the Mudds failed to remit the amounts due with the           
          returns.                                                                    
               Upon the filing of the tax returns described above,                    
          respondent entered assessments against the Mudds for the taxes              
          reported to be due.  See sec. 6201(a)(1).  Respondent also                  
          entered assessments against the Mudds for statutory interest for            
          each of the years in question.                                              
               On November 16, 2000, respondent mailed the Mudds a Final              
          Notice-–Notice of Intent to Levy and Notice of Your Right to a              
          Hearing with regard to their tax liabilities for 1992 to 1997 and           
          1999.  On December 13, 2000, the Mudds filed with respondent a              






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