T.C. Memo. 2006-213 UNITED STATES TAX COURT JOHN N. SWEENEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21167-05L. Filed October 3, 2006. John N. Sweeney, pro se. Monica J. Miller, for respondent. MEMORANDUM OPINION WELLS, Judge: The instant case is before the Court on respondent’s motion for summary judgment pursuant to Rule 1211 and to impose a penalty pursuant to section 6673. The issue we 1Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code.Page: 1 2 3 4 5 6 7 8 Next
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