T.C. Memo. 2006-134
UNITED STATES TAX COURT
DONALD P. ARNETT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18296-04. Filed June 27, 2006.
Donald P. Arnett, pro se.
David W. Sorensen, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for summary judgment and to impose a penalty
under section 6673.1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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