Brian G. Takaba - Page 5




                                        - 5 -                                         
          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.                                                              








Page:  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