Opinion
16752-21S
07-26-2022
ANDREA J. DARNELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
Pursuant to the Opinion of the Court as set forth in the pages of the transcript of the proceedings before Chief Special Trial Judge Lewis R. Carluzzo at Chicago, Illinois, on June 28, 2022, containing his oral findings of fact and opinion, it is
ORDERED that respondent's motion for partial summary judgment, filed March 17, 2022, is recharacterized as a motion for summary judgment. It is further
ORDERED that so much of respondent's motion seeking the imposition of a section 6673 penalty is denied; in all other respects, respondent's motion is granted. It is further
ORDERED and DECIDED that for 2017, there is a $3,835 deficiency in petitioner's Federal income tax, petitioner is liable for a $191.75 addition to tax under I.R.C. Section 6651(a)(1); and petitioner is not liable for an I.R.C. section 6662(a) penalty.