Mazzei v. Comm'r of Internal Revenue

Full title: CELIA MAZZEI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: May 3, 2022

No. 16702-09 (U.S.T.C. May. 3, 2022)

Opinion

16702-09

05-03-2022

CELIA MAZZEI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Michael B. Thornton Judge

ORDER AND DECISION

Michael B. Thornton Judge

Pursuant to the mandate of the Court of Appeals for the Ninth Circuit, filed July 26, 2021, and the determination of this Court as set forth in its Supplemental Memorandum Opinion filed May 2, 2022, it is hereby

ORDERED: That petitioner's Motion for Reasonable Litigation or Administrative Costs filed September 20, 2021, is denied. It is further

DECIDED: That there are no deficiencies in income tax due from petitioner for the taxable years 2002, 2003, 2004, 2005, 2006, and 2007. It is further

DECIDED: That there are no additions to tax under the provisions of I.R.C. section 6651(a)(1) due from petitioner for the taxable years 2002, 2003, 2004, 2005, 2006, and 2007. It is further

DECIDED: That there are no additions to tax under the provisions of I.R.C. section 6651(a)(2) due from petitioner for the taxable years 2002, 2003, 2004, 2005, 2006, and 2007.