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With respect to the imposition of costs on Mr. Sulla, we set
forth the pertinent provisions of section 6673(a)(2) (also
reproduced infra) and stated:
The “Declaration of Paul J. Sulla, Jr.” and
“Petitioner’s Memorandum of Points and Authorities in
Opposition to Motion for Summary Judgment”, signed by
Paul J. Sulla, Jr., both attached to petitioner’s
memorandum, indicate Mr. Sulla’s advocacy of
petitioner’s nonmeritorious positions in this case.
* * *
As stated, we ordered both petitioner and Mr. Sulla to show cause
why they should not be sanctioned under section 6673(a).
Pertinent Events Preceding the 2001 Trial Session
Respondent determined the deficiencies in, and additions to,
tax set forth in the notice on the basis of (1) information
reported to respondent by petitioner’s employer, Thunderbug, and
his bank, American Savings Bank, and (2) the fact that petitioner
did not file any return for 1996 or pay any estimated tax.
The petition was filed on March 22, 1999, petitioner
appearing on his own behalf. Mr. Sulla did not enter his
appearance until June 21, 2000.
By the petition, petitioner denies “having any ‘income’ from
any source for * * * [1996] that is the subject of a tax.” He
denies “being required to file any annual return” for 1996.
Finally, he denies “being liable for any penalties/additions to
tax for” 1996.
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