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Larkin v. Comm'r of Internal Revenue

United States Tax Court
Aug 16, 2023
No. 19940-09 (U.S.T.C. Aug. 16, 2023)

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.


Summaries of

Larkin v. Comm'r of Internal Revenue

United States Tax Court
Aug 16, 2023
No. 19940-09 (U.S.T.C. Aug. 16, 2023)
Case details for

Larkin v. Comm'r of Internal Revenue

Case Details

Full title:DANIEL E. LARKIN & CHRISTINE LARKIN, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Aug 16, 2023

Citations

No. 19940-09 (U.S.T.C. Aug. 16, 2023)