- 2 - respondent filed a Motion to Dismiss for Failure to Properly Prosecute and for a Penalty Under I.R.C. Section 6673 (motion to dismiss). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background Respondent’s determinations at issue in this case are set forth in two separate statutory notices of deficiency, both dated January 26, 2001. The notice for 1996 was addressed to Kyle W. Storks (Storks) and Holly L. Ruocco (petitioner). The deficiency resulted primarily from an increase in income on Schedule C, Profit or Loss From Business, for Canyon State Chiropractic that was explained in the notice for 1996 as follows: 1.B SCH C–CANYON STATE During the taxable period ended December 31, 1996, income earned by you was incorrectly reported by Canyon State Chiropractic and other entities. It is determined that this income from services performed by you in connection with Canyon State Chiropractic and other entities is taxable to you. See enclosed audit report. Taxable income for the taxable period ended December 31, 1996 is increased $217,209.00. The attached audit report showed: (1) The unreported gross receipts or sales of Canyon State Chiropractic for 1996 were determined as the deposits into three bank accounts less the amounts reported on the return as filed and (2) a total ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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