Opinion
19940-09
08-16-2023
DANIEL E. LARKIN & CHRISTINE LARKIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Joseph H. Gale Judge
Pursuant to the determination of this Court as set forth in its Supplemental Memorandum Opinion (T.C. Memo. 2023-106) filed August 16, 2023, it is
ORDERED that the Court's Order and Decision entered September 14, 2017, is hereby vacated and set aside. It is further
ORDERED that respondent's Further Revised Computation for Entry of Decision, filed April 18, 2022, is incorporated as the findings of the Court to the extent that it is consistent with respondent's Revised Computation for Entry of Decision, filed July 16, 2021. It is further
ORDERED and DECIDED that, without taking into consideration any assessments subsequent to the entry of the Court's Order and Decision on September 14, 2017, there are deficiencies in income tax due from petitioners for the taxable years 2005 and 2006 in the amounts of $95,995.00 and $99,534.00, respectively;
That there is an addition to tax due from petitioners for the taxable year 2005 under the provisions of I.R.C. § 6651(a)(1) in the amount of $9,599.50; and
That there are penalties due from petitioners for the taxable years 2005 and 2006 under the provisions of I.R.C. § 6662(a) in the amounts of $19,199.00 and $19,906.80, respectively.