Opinion
13097-15
03-11-2022
David W. Walters & Jean T. Walters Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Thomas B. Wells Judge
Pursuant to the Court's opinion at T.C. Memo. 2022-17, filed March 7, 2022, it is
ORDERED that petitioners' oral motion to shift the burden of proof, made at trial on September 25, 2017, is denied as moot. It is further
ORDERED that respondent's motion to reopen the record, filed January 26, 2018, is denied as moot. It is further
ORDERED and DECIDED that there are no deficiencies in income tax due from, nor overpayments due to, petitioners for the taxable years 2011 and 2012. There is no penalty pursuant to I.R.C. Section 6662(a) due from petitioners for the taxable year 2011.