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DEPUTY v. COMMISSIONER

Docket No. 8183-02L.

86 T.C.M. 87 (2003)

T.C. Memo. 2003-210

Robert H. Deputy v. Commissioner

United States Tax Court.

Filed July 16, 2003.

Attorney(s) appearing for the Case

Robert H. Deputy, pro se. Minakshi Tyagi-Jayasinghe, for the respondent.

MEMORANDUM OPINION

GERBER, Judge.

Respondent, on March 10, 2003, moved for summary judgment on two questions: (1) Whether respondent may proceed with collection of various income taxes and penalties assessed against petitioner and (2) whether petitioner is liable for a penalty under section 66731 because this proceeding was instituted or maintained for delay and/or petitioner's position is frivolous. Petitioner filed responses...

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