Henry Uscinski and Jacqueline Uscinski - Page 8

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          repeated motions for summary judgment.  This argument is without            
          merit.  Rule 121 does not prevent successive motions for summary            
          judgment.                                                                   
               We conclude that petitioners are liable for the 10-percent             
          additional tax under section 72(t).                                         
               To reflect the foregoing and respondent’s concessions,                 


                                                  An appropriate order and            
                                             decision will be entered.                






























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