T.C. Memo. 2003-11
UNITED STATES TAX COURT
ROBERT GUNSELMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6925-02L. Filed January 9, 2003.
Robert Gunselman, pro se.
James Brian Urie, for respondent.
MEMORANDUM OPINION
RUWE, Judge: This matter is before us on respondent’s
motion for summary judgment under Rule 1211 and to impose a
penalty under section 6673. Respondent argues that no genuine
issue exists as to any material fact and that his determination
1All section references are to the Internal Revenue Code as
amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011