- 2 - MEMORANDUM OPINION VASQUEZ, Judge: These consolidated cases are before the Court on respondent’s motions to dismiss for lack of prosecution pursuant to Rule 123(b),2 motion for partial summary judgment, and motion for damages under section 6673(a)(1). By separate notices of deficiency, respondent determined the following deficiencies in and penalties on petitioners’ Federal income taxes:3 Walter J. Ward (Mr. Ward) and Virginia L. Ward (together, the Wards): Penalty Year Deficiency Sec. 6662(a) 1996 $197,521 $39,504 1997 209,127 41,825 Alaska Statewide Investors Co. Trust (ASI), Daniel A. Carvalho, Trustee: Penalty Year Deficiency Sec. 6662(a) 1996 $110,561 $22,112 1997 125,944 25,189 2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 3 For convenience, figures are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011