- 3 -
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s motion for summary judgment, filed
pursuant to Rule 121. As discussed in detail below, we shall
grant respondent’s motion.
Background2
In Beery v. Commissioner, T.C. Memo. 1996-464 (docket No.
26995-93), we sustained respondent’s determination that Joyce
Beery (petitioner) and her husband were liable for tax
deficiencies and accuracy-related penalties for 1989, 1990, and
1991. In Beery v. Commissioner, docket No. 8802-96, we sustained
respondent’s determination that petitioner was liable for tax
deficiencies for 1992, 1993, and 1994. The Court’s decision in
docket No. 8802-96 was affirmed on appeal by unpublished opinion.
See Beery v. Commissioner, 166 F.3d 346 (10th Cir. 1998).
On August 14, 2002, respondent issued to petitioner a final
notice disallowing her claims for relief from joint and several
liability on a joint return for the taxable years 1989 to 1994.
On November 12, 2002, petitioner filed with the Court a timely
2 The record reflects and/or the parties do not dispute the
following facts.
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