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the Court’s trial calendar (calendar call) at the Court’s trial
session in Cleveland, Ohio (Cleveland trial session). At that
calendar call, there was no appearance by or on behalf of Rich-
ards Management Trust in the case at docket No. 10764-00, Mr.
Richards in the cases at docket Nos. 10765-00 and 10766-00, and
Richards Charitable Trust in the case at docket No. 10767-00. At
that time, respondent orally moved to dismiss each of these cases
for failure to prosecute, and respondent requested, and the Court
held, a trial because, according to respondent, respondent had
the burden of production pursuant to section 7491(c)5 with re-
spect to (1) the accuracy-related penalties under section 6662(a)
for 1996 and 1997 that respondent determined against Richards
Management Trust in the case at docket No. 10764-00, (2) the
respective accuracy-related penalties under section 6662(a) for
1996 and 1997 that respondent determined against Mr. Richards in
the cases at docket Nos. 10765-00 and 10766-00, and (3) the
additions to tax under section 6651(a)(1) for 1996 and 1997 that
respondent determined against Richards Charitable Trust in the
case at docket No. 10767-00.
At the trial in these cases on October 15, 2001, there was
no appearance by or on behalf of Richards Management Trust, Mr.
5All section references are to the Internal Revenue Code in
effect at all relevant times. Unless otherwise indicated, all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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