- 2 - 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 onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011