Opinion
16702-09
05-03-2022
CELIA MAZZEI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
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.