T.C. Memo. 2003-125 UNITED STATES TAX COURT DANIEL AND SALLY A. HOLGUIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10215-02L. Filed April 29, 2003. Daniel Holguin and Sally A. Holguin, pro sese. Alan J. Tomsic, for respondent. MEMORANDUM OPINION CHIECHI, Judge: This case is before the Court on respon- dent’s motion for summary judgment and to impose a penalty under section 66731 as to petitioner Daniel Holguin (respondent’s 1All section references are to the Internal Revenue Code in effect at all relevant times. 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 13 14 15 Next
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