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