T.C. Memo. 2002-235
UNITED STATES TAX COURT
ROBERT R. VILLWOCK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10245-01L. Filed September 19, 2002.
Robert R. Villwock, pro se.
Wendy S. Harris and Karen Lynne Baker, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s motion for summary judgment and to
impose a penalty under I.R.C. section 6673, filed pursuant to
Rule 121.1 Respondent contends that there is no dispute as to
1 Unless otherwise indicated all section references are to
the Internal Revenue Code, as amended, and all Rule references
(continued...)
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