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MOORE v. COMMISSIONER

Docket No. 28004-91.

64 T.C.M. 254 (1992)

T.C. Memo. 1992-415

Diana L. Moore v. Commissioner

United States Tax Court.

Filed July 21, 1992.

Attorney(s) appearing for the Case

Diana L. Moore, pro se. William F. Halley, for the respondent.

Memorandum Opinion

GUSSIS, Special Trial Judge:

This case is before the Court on respondent's motion to dismiss for failure to state a claim for relief pursuant to Rule 40 and for damages (now designated as a penalty) under section 6773(a)(1). See sec. 7443A(b)(4). All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.

Respondent determined...

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