T.C. Memo. 2005-39
UNITED STATES TAX COURT
WILLIAM C. STEARMAN III, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 20928-03, 15561-04. Filed March 3, 2005.
William C. Stearman III, pro se.
Donna B. Read, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: These cases are before the Court on
respondent’s motions to dismiss for failure to state a claim upon
which relief could be granted and to impose a penalty under
section 6673(a).1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
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