Nis Family Trust v. Commissioner
United States Tax Court
The cases are before the Court on R's motions for judgment on the pleadings and partial summary judgment and on the Court's orders to show cause why it should not (1) impose penalties on Ps for instituting or maintaining proceedings primarily for delay or for advancing frivolous or groundless positions, and (2) require Ps' attorney, S, to pay excess costs, expenses, and fees for her bad faith course of conduct by which she unreasonably and vexatiously multiplied these…
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The cases are before the Court on R's motions for judgment on the pleadings and partial summary judgment and on the Court's orders to show cause why it should not (1) impose penalties on Ps for instituting or maintaining proceedings primarily for delay or for advancing frivolous or groundless positions, and (2) require Ps' attorney, S, to pay excess costs, expenses, and fees for her bad faith course of conduct by which she unreasonably and vexatiously multiplied these proceedings. In the petitions, Ps fail to address any of the adjustments made in the notices of deficiency, raising only…
1Opinion of the Court
OPINION
HAlpern, Judge:
These cases have been consolidated for trial, briefing, and opinion (the consolidated cases or these cases). Respondent has determined deficiencies in income tax and accuracy-related penalties under section 6662 as follows:
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These cases are before the Court on (1) respondent’s motions for (A) judgment on the pleadings and (B) partial summary judgment and (2) the Court’s orders to show cause why it should not impose (A) penalties on petitioners pursuant to section 6673(a)(1) and (B) require counsel for petitioners, Crystal D. Sluyter, to pay costs, expenses,…
2Cases cited19 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Neely v. CommissionerUnited States Tax Court · 1985
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Golden Eagle Distributing Corporation v. Burroughs Corporation, and Kirkland & EllisCourt of Appeals for the Ninth Circuit · 1986
- Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
14 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Swain v. Comm'rUnited States Tax Court · 2002
- Takaba v. Comm'rUnited States Tax Court · 2002
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
- CORCORAN v. COMMISSIONERUnited States Tax Court · 2002
- Johnson v. CommissionerUnited States Tax Court · 2001
44 more not listed; retrieve them via the Exa API.