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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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