T.C. Memo. 2005-71
UNITED STATES TAX COURT
W. JAMES KUBON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1795-04L. Filed April 4, 2005.
W. James Kubon, pro se.
Gavin L. Greene, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This case is before the Court on
respondent’s motion for summary judgment filed pursuant to Rule
121 and to impose a penalty under section 6673.1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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