No. 02-14128 Non-Argument Calendar.

329 F.3d 1224 (2003)

Thomas W. ROBERTS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

March 13, 2003.

Attorney(s) appearing for the Case

Thomas W. Roberts, Winter Park, FL, pro se.

Teresa E. McLaughlin, Randolph L. Hutter, John Schumann, Dept. of Justice, Washington, DC, for Respondent-Appellee.

Before ANDERSON, BIRCH and BLACK, Circuit Judges.


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...

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