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.
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