T.C. Memo. 2002-140
UNITED STATES TAX COURT
DAVID AND THERESA SMETON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4671-01L. Filed June 3, 2002.
David and Theresa Smeton, pro sese.
Wendy S. Harris and Sheara L. Gelman, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion For Summary Judgment And To Impose A
Penalty Under I.R.C. Section 6673, filed pursuant to Rule 121.1
Respondent contends that there is no dispute as to any material
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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