Brian G. Takaba - Page 2




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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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