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Williams v. Comm'r of Internal Revenue

United States Tax Court
Jan 19, 2023
No. 9252-21 (U.S.T.C. Jan. 19, 2023)

Opinion

9252-21

01-19-2023

ANDREW O. WILLIAMS AND KATHRYN S. WILLIAMS, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER AND DECISION

Tamara W. Ashford, Judge

By Order served on the parties on December 2, 2022, the Court granted respondent's Motion to Dismiss for Lack of Prosecution, filed September 22, 2022, and as supplemented on November 29, 2022, dismissing this case as to petitioner Andrew O. Williams. On December 23, 2022, petitioner Kathryn S. Williams and respondent filed a Proposed Stipulated Decision, resolving all issues with respect to Mrs. Williams. Upon due consideration, it is hereby

ORDERED that the Clerk of the Court shall recharacterize petitioner Kathryn S. Williams and respondent's Proposed Stipulated Decision, filed December 23, 2022, and referenced as docket entry number 39, as a Settlement Stipulation. It is further

ORDERED and DECIDED that there are deficiencies in income tax, penalties, and additions to tax due from petitioner Andrew O. Williams as follows:

Year

Deficiency

Addition to Tax I.R.C. § 6651(a)(1)

Addition to Tax I.R.C. § 6651(a)(2)

Addition to Tax I.R.C. § 6654

Penalty I.R.C. § 6662

2010

$105,627.00

$0.00

$0.00

$0.00

$21,125.40

2011

$95,058.00

$0.00

$0.00

$0.00

$19,011.60

2012

$89,281.00

$0.00

$0.00

$0.00

$17,856.20

2013

$64,135.00

$0.00

$0.00

$0.00

$12,806.00

2014

$50,312.00

$0.00

$0.00

$0.00

$10,062.40

2015

$52,811.00

$0.00

$0.00

$0.00

$10,562.20

2016

$90,112.00

$20,275.20

$19,824.64

$0.00

$0.00

2017

$48,936.00

$11,010.60

$7,829.76

$1,171.65

$0.00

It is further

ORDERED and DECIDED that there are deficiencies in income tax and penalties due from petitioner Kathryn S. Williams, before application of I.R.C. § 6015(c), as follows:

Year

Deficiency

Penalty I.R.C. § 6662

2010

$105,627.00

$21,125.40

2011

$95,058.00

$19,011.60

2012

$89,281.00

$17,856.20

2013

$64,135.00

$12,806.00

2014

$50,312.00

$10,062.40

2015

$52,811.00

$10,562.20

It is further

ORDERED and DECIDED that there are deficiencies in income tax and penalties due from petitioner Kathryn S. Williams, after application of I.R.C. § 6015(c), as follows:

Year

Deficiency

Penalty I.R.C. § 6662

2010

$4,492.00

$0.00

2011

$0.00

$0.00

2012

$4,450.00

$0.00

2013

$5,160.00

$0.00

2014

$4,053.00

$0.00

2015

$3,675.00

$0.00

It is further

ORDERED and DECIDED that there are no overpayments due to petitioner Kathryn S. Williams for the 2010-2015 taxable years.


Summaries of

Williams v. Comm'r of Internal Revenue

United States Tax Court
Jan 19, 2023
No. 9252-21 (U.S.T.C. Jan. 19, 2023)
Case details for

Williams v. Comm'r of Internal Revenue

Case Details

Full title:ANDREW O. WILLIAMS AND KATHRYN S. WILLIAMS, Petitioners, v. COMMISSIONER…

Court:United States Tax Court

Date published: Jan 19, 2023

Citations

No. 9252-21 (U.S.T.C. Jan. 19, 2023)