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shall grant respondent’s motion in the case at docket No. 10765-
00 and respondent’s motion in the case at docket No. 10766-00 in
that we shall dismiss each of those cases for failure by peti-
tioner in each such case to prosecute such case, and we shall
enter a decision in each of those cases sustaining the determina-
tions that respondent made in the notice to which each such case
pertains but in the reduced amounts which respondent concedes are
appropriate in order to reflect the duplication of certain income
determinations in the respective notices issued to Mr. Rich-
ards.15
In respondent’s motions in the cases at docket Nos. 10765-00
and 10766-00, respondent also asks the Court to impose a penalty
15As explained in respondent’s respective motions in the
cases at docket Nos. 10765-00 and 10766-00, respondent attributed
the income reported for the taxable year 1996 by Richards Manage-
ment Trust 100 percent to Joy A. Richards, deceased, Mr. Rich-
ards, and Richards Charitable Trust, and respondent attributed
the income reported for the taxable year 1997 by Richards Manage-
ment Trust 100 percent to Mr. Richards and Richards Charitable
Trust. The amounts of such income attributed to Richards Chari-
table Trust for 1996 were reattributed for that year to Mr.
Richards, and the amounts of such income attributed to Richards
Charitable Trust for 1997 were reattributed to Mr. Richards,
which resulted in a duplication of said amounts of income in the
respective notices issued to Mr. Richards with respect to the
taxable year 1996 and to Mr. Richards with respect to the taxable
year 1997. As set forth in respondent’s respective motions in
the cases at docket Nos. 10765-00 and 10766-00 and in the respec-
tive exhibits attached to those motions, the revised deficiencies
for Mr. Richards for the taxable years 1996 and 1997 are $33,451
and $75,934, respectively. Consistently, the revised accuracy-
related penalties under sec. 6662(a) imposed on Mr. Richards for
the taxable years 1996 and 1997 are $6,690.20 and $15,186.80,
respectively.
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