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.Page: 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007