T.C. Memo. 2002-135
UNITED STATES TAX COURT
GENE AND CIAO NEWMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5695-01L. Filed May 30, 2002.
Gene and Ciao Newman, pro sese.
Wendy S. Harris and Karen Lynne Baker, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion For Summary Judgment And To Impose A
Penalty Under I.R.C. Section 6673, as supplemented.1 Respondent
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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