United States Tax Court December 4, 2000, No. 9820-99; No. 9821-99; No. 9822-99 (Nis Family Trust v. Commissioner)

lead-opinion

OPINION

HAlpern, Judge:

These cases have been consolidated for trial, briefing, and opinion (the consolidated cases or these cases). Respondent has determined deficiencies in income tax and accuracy-related penalties under section 6662 as follows:

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These cases are before the Court on (1) respondent’s motions for (A) judgment on the pleadings and (B) partial summary