Richards Asset Management Trust, et al. - Page 2




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          No. 10764-00), respondent’s motion to dismiss for lack of prose-            
          cution and to impose sanctions under section 66732 in the case at           
          docket No. 10765-00 (respondent’s motion in the case at docket              
          No. 10765-00), respondent’s motion to dismiss for lack of prose-            
          cution and to impose sanctions under section 6673 in the case at            
          docket No. 10766-00 (respondent’s motion in the case at docket              
          No. 10766-00), and respondent’s motion to hold petitioner in                
          default in the case at docket No. 10767-00 (respondent’s motion             
          in the case at docket No. 10767-00).  (We shall refer collec-               
          tively to those four motions as respondent’s motions.)  At the              
          request of respondent, on October 15, 2001, the Court held a                
          trial in order to enable respondent to present evidence to                  
          satisfy the burden of production under section 7491(c) that                 
          respondent maintains respondent has with respect to:  (1) The               
          accuracy-related penalty under section 6662(a) that respondent              
          determined for each of the taxable years 1996 and 1997 in the               
          notice of deficiency (notice) issued to Richards Asset Management           
          Trust (Richards Management Trust)3 in the case at docket No.                
          10764-00; (2) the accuracy-related penalty under section 6662(a)            


               2All section references are to the Internal Revenue Code               
          (Code) in effect at all relevant times.  All Rule references are            
          to the Tax Court Rules of Practice and Procedure.                           
               3When referring in this Opinion to Richards Asset Management           
          Trust and Richards Management Trust, our use of the word “Trust”            
          and any similar words is for convenience only and is not intended           
          to convey any meaning or have any significance for Federal tax              
          purposes.                                                                   





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