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.