Thomas W. Roberts v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Non-Argument Calendar.
1Per curiam
Thomas W. Roberts appeals the Tax Court’s grant of partial summary judgment in favor of the Commissioner of Internal Revenue (“Commissioner”) on his petition challenging a tax assessment. He also challenges the assessment of a $10,000.00 penalty for maintaining this action for delay. Because the Tax Court: (1) correctly determined that the appeals officer verified the existence of the assessment, and (2) did not abuse its discretion in imposing sanctions, we AFFIRM.
I. BACKGROUND
Roberts reported a tax liability on his 1996 tax return, but did not pay the amount with his return. The…
2Cases cited7 opinions
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