T.C. Summary Opinion 2004-155
UNITED STATES TAX COURT
LAURA A. GAVIGAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13779-03S. Filed November 10, 2004.
Laura A. Gavigan, pro se.
Luanne S. Di Mauro, for respondent.
WOLFE, Special Trial Judge: This matter is before the Court
on respondent’s motion for summary judgment and to impose a
penalty under section 6673 (motion).1 It was heard pursuant to
the provisions of section 7463. The decision to be entered is
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at relevant times, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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