T.C. Memo. 2004-72
UNITED STATES TAX COURT
EARLY ROBERTSON, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10113-02L. Filed March 18, 2004.
In a collection proceeding, R issued a notice of
determination with respect to P’s 1995 through 1999
taxable years. After P petitioned this Court for
review, R filed a motion for summary judgment.
Held: R’s motion for summary judgment will be
granted as to 1995 and 1996. P received a notice of
deficiency for those years and has not raised any
material issues regarding an abuse of discretion by R.
Held, further, R’s motion for summary judgment
will be denied as to 1997. P is entitled to challenge
his self-reported liabilities for that year and has
raised a question of material fact with respect
thereto.
Held, further, R’s motion for summary judgment
will be granted as to 1998 and 1999. P has not raised
any material issues of fact with respect to his
underlying liabilities for those years or with respect
to any abuse of discretion by R.
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