T.C. Memo. 2004-192
UNITED STATES TAX COURT
ROBERT & POLLY A. GATLOS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15827-03L. Filed August 26, 2004.
Robert and Polly A. Gatlos, pro sese.
Jeffrey C. Venzie, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion for summary judgment, filed pursuant to Rule
121,1 and to impose a penalty under section 6673.
Summary judgment is a procedure designed to expedite
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the years at issue.
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