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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.
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Last modified: May 25, 2011