Campbell v. Comm'r

ALFRED Q. CAMPBELL III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Campbell v. Comm'r

Docket No. 13687-11L

United States Tax Court

T.C. Memo 2012-82; 2012 Tax Ct. Memo LEXIS 82; 103 T.C.M. (CCH) 1446;

March 22, 2012, Filed

Alfred Q. Campbell III, Pro se.

Martha Jane Weber, for respondent.

WELLS, Judge.

WELLS

MEMORANDUM OPINION

WELLS, Judge: This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121 and to impose a penalty pursuant to section 6673. 1 The issues we have been asked to decide are: (1) whether petitioner is precluded from contesting his…