T.C. Memo. 2002-242 UNITED STATES TAX COURT WILLIAM WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14224-01L. Filed September 25, 2002. William Wilson, pro se. Alan J. Tomsic and Robin M. Ferguson, 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, as supplemented, filed pursuant to Rule 121.1 Respondent contends that there is 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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