T.C. Memo. 2003-6 UNITED STATES TAX COURT JEFFREY M. YOUNG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1193-02L. Filed January 8, 2003. Jeffrey M. Young, pro se. Jeffrey C. Venzie, for respondent. MEMORANDUM OPINION RUWE, Judge: This matter is before us on respondent’s motion for summary judgment under Rule 1211 and to impose a penalty under section 6673. Respondent argues that no genuine issue exists as to any material fact and that his determination 1All Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code as amended.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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