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PEPPER POT TRUST v. COMMISSIONER

Docket Nos. 9111-02L, 9112-02L, 9113-02L, 9447-02L.

86 T.C.M. 443 (2003)

T.C. Memo. 2003-287

Pepper Pot Trust, David-Keith Jacobs, Trustee v. Commissioner.

United States Tax Court.

Filed October 7, 2003.

Attorney(s) appearing for the Case

David-Keith Jacobs (Trustee), for the petitioners.

Huong T. Duong, for the respondent.

MEMORANDUM OPINION

COLVIN, Judge:

This matter is before the Court on respondent's motions to dismiss for lack of prosecution, and for summary judgment and to impose a penalty on each trust under section 6673.2 Respondent filed motions for summary judgment and to impose a penalty under section 6673 in each case. Respondent made the motion to dismiss at the time set for trial, for...

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