Martin v. Commissioner
United States Tax Court
Respondent moved to dismiss this case for failure properly to prosecute both as to the underlying deficiencies and additions to tax under secs. 6651(a)(1) and 6653(a), I.R.C. 1954, claimed in respondent's answer and as to which he has the burden of proof. Held, respondent's motion is granted. Bosurgi, Transferee v. Commissioner, 87 T.C. 1403 (1986), applied.
1Opinion of the Court
Jane A. Martin, Petitioner v. Commissioner of Internal Revenue, Respondent
Martin v. Commissioner
Docket No. 7228-86
United States Tax Court
1987 U.S. Tax Ct. LEXIS 150; 89 T.C. No. 61; 89 T.C. 894;
October 22, 1987. October 22, 1987, Filed
An appropriate order and decision will be entered for the respondent.
Respondent moved to dismiss this case for failure properly to prosecute both as to the underlying deficiencies and additions to tax under secs. 6651(a)(1) and 6653(a), I.R.C. 1954, claimed in respondent's answer and as to which he has the burden of proof. Held, respondent's motion is granted.…
2Cases cited2 opinions
- Bosurgi v. CommissionerUnited States Tax Court · 1986
- Martin v. CommissionerUnited States Tax Court · 1987