Opinion
14765-15L
03-03-2023
ALLEN R. DAVISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph W. Nega Judge
On February 17, 2023, respondent filed a motion for leave to file out of time a motion to correct the decision in this case, entered on March 5, 2021, and on the same day, lodged a motion for an order correcting the decision. Respondent's motion to correct the decision asserts that: (1) the entered decision contains a typographical error, erroneously referring to penalties under I.R.C. section 6707, and (2) although the validity and amount of the underlying liabilities were at issue in this case, the entered decision does not include the Court's determination of the correct amount of the liabilities that were at issue in this case.
Upon due consideration and for cause, it is
ORDERED that respondent's motion for leave to file out of time a motion to correct the decision is granted, and the motion for an order correcting the decision, lodged February 17, 2023, is filed as of the date of service of this order. It is further
ORDERED that respondent's motion for an order correcting the decision is granted, in that we shall correct the erroneous reference in the decision to section 6707. It is further
ORDERED that the Court's decision, entered on March 5, 2021, is vacated and set aside.