Opinion
2670-19
11-16-2022
JOHN E. VORREYER & MELISSA D. VORREYER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Travis A. Greaves, Judge
Petitioners' Motion for Partial Summary Judgment filed September 30, 2022, asks the Court to deny section 6662(a) accuracy-related penalties proposed in the notices of deficiency on the ground that there was substantial authority for petitioners' treatment of disputed items under section 6662(d)(2)(B)(i). Respondent's response to the Motion, filed November 2, concedes the penalties based on section 6751(b)(1).
It is therefore
ORDERED that petitioners' Motion is denied as moot.