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ROMANO v. COMMISSIONER

Docket No. 25983-82.

48 T.C.M. 1472 (1984)

T.C. Memo. 1984-568

Enrico Michael Romano v. Commissioner.

United States Tax Court.

Filed October 23, 1984.

Attorney(s) appearing for the Case

Enrico Michael Romano, pro se., Oceanside, Calif. Mark S. Priver and Charles E. Williams, for the respondent.

Memorandum Opinion

CANTREL, Special Trial Judge:

This case is before the Court on respondent's Motion for Sanctions under Rule 104(c)(3), Tax Court Rules of Practice and Procedure, which motion was filed on August 30, 1984.1

Respondent, in his notice of deficiency issued to petitioner on July 30, 1982, determined a deficiency in petitioner's Federal income tax and an addition to the tax under section 6651(a)

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