Opinion
2207-18
12-28-2023
CONMAC INVESTMENTS INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Elizabeth Crewson Paris, Judge.
On February 13, 2019, respondent filed with the Court a Motion for Summary Judgment; and a Memorandum in Support of Motion for Summary Judgment, docket entries 30 and 31.
On April 19, 2019, petitioner filed an Opposition to Motion for Summary Judgment, a cross Motion for Summary Judgment, Petitioner's Memorandum of Law in Support of Petitioner's Cross-Motion for Summary Judgment, and supporting affidavits, at docket entries 35 through 41.
On January 19, 2023, docket entry 52, respondent filed a First Supplemental Memorandum in support of Motion for Summary Judgment. And, also on January 19, 2023, docket entry 53, petitioner filed a First Supplemental Memorandum of Law in Support of Petitioner's Cross-Motion for Summary Judgment.
On March 27, 2023, docket entry 55, the Court issued a Memorandum Opinion (T.C. Memo. 2023-40), which reflects that the Court will grant respondent's Motion for Summary Judgment and deny petitioner's Cross-Motion for Summary Judgment. Because respondent's Second Amendment to Answer increased the deficiency for 2013 as determined in the notice of deficiency, the parties were ordered to submit a Rule 155 computation. On October 2, 2023, docket entry 65, the parties filed a Computation for Entry of Decision.
After due consideration, it is
ORDERED that, respondent's Motion for Summary Judgment, filed February 13, 2019, docket entry 30, is granted. It is further
ORDERED that, petitioner's Cross-Motion for Summary Judgment, filed April 19, 2019, docket entry 36, is denied. It is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2013 in the amount of $117,538; and
That there is a deficiency in income tax due from petitioner for the taxable year 2014 in the amount of $114,042.