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summary judgment and to impose a penalty on each trust under
section 6673.2 Respondent filed motions for summary judgment and
to impose a penalty under section 6673 in each case. Respondent
made the motion to dismiss at the time set for trial, for which
David-Keith Jacobs (Jacobs), the trustee of each trust, failed to
appear.3 For reasons stated below, we will grant respondent’s
motion to dismiss for lack of prosecution and so much of
respondent’s motions for summary judgment and to impose a penalty
under section 6673 as asks us to impose a penalty on each trust
under section 6673.4
Background
The trusts’ mailing address was in Clovis, California, when
the petitions were filed.
A. Notices of Deficiency, Notices of Intent To Levy, and
Federal Tax Liens
The trusts received notices of deficiency determining
deficiencies in the fiduciary income taxes of each trust for
1996-97.
2 Section references are to the Internal Revenue Code as
amended, and Rule references are to the Tax Court Rules of
Practice and Procedure.
3 No one representing any of the trusts in these cases
appeared for trial.
4 We will deny as moot so much of respondent’s motions for
summary judgment and to impose a penalty under sec. 6673 as asks
for summary judgment.
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Last modified: May 25, 2011