Opinion
16305-17S
01-05-2022
Dion E. Monroe & Kim M. Monroe Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Elizabeth A. Copeland, Judge
On August 11, 2021, the Court issued its Summary Opinion in this case (T.C. Summary Opinion 2021-24), which stated at the end thereof that "Decision will be entered under Rule 155." By Order dated August 16, 2021, the Court directed the parties to file with the Court by October 12, 2021, their computations in this case, pursuant to Rule 155, Tax Court Rules of Practice and Procedure.
On October 12, 2021, respondent filed with the Court a document titled Respondent's Computation for Entry of Decision (docket index entry No. 27) attaching thereto a computation statement and a proposed decision document. On the same date, respondent filed a second document titled Respondent's Computation for Entry of Decision (docket index entry No. 28) attaching thereto the same computation statement and proposed decision document, but also attaching Form 5278, Statement-Income Tax Changes and Form 4549-B, Report of Income Tax Examination Changes and related schedules. Respondent's second filing (docket index entry No. 28) is more complete and therefore the Court will strike the first filing (docket index entry No. 27) from the Court's record.
Respondent's Rule 155 computations and the proposed decision document were served on petitioners on October 12, 2021. Petitioners did not submit to the Court their own alternative Rule 155 computations by the October 12, 2021, deadline and have not done so to date. Petitioners have likewise not expressed disagreement with respondent's computations.
In reviewing respondent's computations, we can find no error in and thus accept them.
Upon due consideration, it is
ORDERED that Respondent's Computation for Entry of Decision (docket index entry No. 27), filed October 12, 2021, is hereby stricken from the Court's record in this case. It is further
ORDERED AND DECIDED: That there are deficiencies in income tax due from petitioners for the taxable years 2014 and 2015 in the amounts of $12,718.00 and $11,561.00, respectively; and
That there are penalties due from petitioners for the taxable years 2014 and 2015, under the provisions of I.R.C. § 6662(a), in the amounts of $2,407.20 and $2,312.20, respectively.