Pepper Pot Trust, David-Keith Jacobs, Trustee - Page 2

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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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