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MIRAVALLE v. COMMISSIONER

Docket No. 9870-91.

67 T.C.M. 2127 (1994)

T.C. Memo. 1994-49

Donald J. Miravalle and Lillian Joy Miravalle v. Commissioner.

United States Tax Court.

Filed February 9, 1994.

Attorney(s) appearing for the Case

Donald J. Miravalle and Lillian Joy Miravalle, pro se. Howard P. Levine, for the respondent.

Memorandum Opinion

GERBER, Judge:

Respondent moved for summary judgment under Rule 121.1 By Order, dated October 20, 1993, petitioners were required to respond to respondent's motion for summary judgment, but they failed to respond. Respondent, by the summary judgment motion, seeks to establish the income tax deficiencies and additions to tax and obviate the need for a trial. With respect to the additions to tax under section...

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