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HARRY v. COMMISSIONER

Docket No. 17360-91.

66 T.C.M. 519 (1993)

T.C. Memo. 1993-388

Harry and Rose Richman v. Commissioner.

United States Tax Court.

Filed August 25, 1993.

Attorney(s) appearing for the Case

Jared J. Scharf, 11 Martine Ave., White Plaines, N.Y., for the petitioners. William J. Gregg, for the respondent.

Memorandum Opinion

LARO, Judge:

Petitioners move pursuant to Rule 121 for an order granting summary judgment in their favor (Present Motion).1 Petitioners allege in the Present Motion that respondent cannot meet her burden of proving by clear and convincing evidence that petitioners filed false or fraudulent returns with the intent to evade tax under section 6501(c)(1) or section...

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