Robert S. Brooks - Page 1

                                 T.C. Memo. 2007-80                                   

                               UNITED STATES TAX COURT                                

                           ROBERT S. BROOKS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No.  24689-04.             Filed April 4, 2007.                      

                    P failed to file an income tax return or pay any amount           
               of Federal income tax for 2002.  R issued a notice of                  
               deficiency for the amount of the income tax plus additions             
               to tax.  P filed a petition for review of the deficiency,              
               and both parties have moved for summary judgment.                      

                    Held:  Summary judgment in favor of R is appropriate              
               with respect to P’s liability for the Federal income tax               
               plus the addition to tax for failure to file a return.                 
               Summary judgment is not appropriate for the additions to tax           
               for failure to pay tax shown on a return or failure to make            
               estimated tax payments.                                                

               Robert S. Brooks, pro se.                                              
               Innessa Glazman-Molot, for respondent.                                 

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Last modified: November 10, 2007