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GRUNSTED v. COMMISSIONER

Docket No. 12954-09L.

136 T.C. 455 (2011)

SCOTT GRUNSTED, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 11, 2011.

Attorney(s) appearing for the Case

Scott Grunsted , pro se.

Lisa M. Oshiro and Melanie Senick , for respondent.

OPINION

KROUPA, Judge:

This collection review matter is before the Court on respondent's motion for summary judgment under Rule 121.1 The first issue for decision is whether petitioner is liable for the five frivolous return penalties assessed for the 2002, 2003 and 2004 tax years (the years at issue). We find that he is liable. The second issue for decision is whether respondent's determination to proceed with the proposed...

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