Johnson v. Commissioner
United States Tax Court
HELD: Petitions by J, individually and as trustee, are dismissed for lack of prosecution. Attorney's fees are awarded under I.R.C. sec. 6673(a)(2) against petitioners' counsel, who multiplied the proceedings unreasonably and vexatiously.
1Opinion of the Court
OPINION
Cohen, Judge:
In the case at docket No. 6452-99, respondent determined deficiencies of $12,476 and $15,260 and accuracy-related penalties under section 6662(a) of $2,495.20 and $3,052 with respect to Federal income taxes of petitioner Shirley L. Johnson (Johnson) for 1996 and 1997, respectively. The deficiencies and penalties were attributable to adjustments related to Johnson’s receipt of income from NJSJ Asset Management Trust (NJSJ Trust).
In the case at docket No. 6453-99, respondent determined deficiencies of $14,056 and $17,593 and accuracy-related penalties under section 6662(a)…
2Cases cited12 opinions
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Zmuda v. CommissionerUnited States Tax Court · 1982
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- Estate of Ming v. CommissionerUnited States Tax Court · 1974
- Nis Family Trust v. CommissionerUnited States Tax Court · 2000
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