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Paul J. Sulla, Jr., for petitioner.
David Lau, for respondent.
OPINION
HALPERN, Judge: This case is before the Court to consider
whether petitioner must pay a penalty pursuant to section
6673(a)(1) and whether petitioner’s counsel, Paul J. Sulla, Jr.
(Mr. Sulla), must pay certain of respondent’s costs pursuant to
section 6673(a)(2). For the reasons that follow, the Court shall
impose on petitioner a penalty of $15,000 and on Mr. Sulla a
liability of $10,500.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Previous Proceedings
Previously, this case was before the Court on respondent’s
motions for summary judgment and to award damages (the motions
for summary judgment and for damages, respectively). By order
dated June 6, 2001 (the June 6 order), we granted the motion for
summary judgment, took under advisement the motion for damages,
and ordered petitioner and Mr. Sulla to prepare to show cause why
a penalty under section 6673(a)(1) should not be imposed on
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Last modified: May 25, 2011