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.
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