- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011