Opinion
16784-18
06-02-2023
JOSEPH DECRESCENZO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
James S. Halpern, Judge
Pursuant to the determination of the Court's Memorandum Opinion (T.C. Memo. 2023-7) filed January 12, 2023, and incorporating herein the facts recited in respondent's computations, it is
ORDERED that petitioner's February 11, 2020, oral motion to Dismiss for Lack of Jurisdiction is denied. It is further
ORDERED that respondent's February 11, 2020, oral motion to impose sanctions is granted, in that, there is a penalty due from petitioner, under the provisions of I.R.C. § 6673(a)(1), in the amount of $5,000. It is further
ORDERED AND DECIDED: That there are deficiencies in income tax, additions to tax, and penalties due from petitioner as follows:
Tax Year Deficiency Additions to tax § 6651(a)(1) § 6662(a) 2007 $5,287.00 $1,321.75 -0- 2008 19,566.00 4,891.50 -0- 2009 8,765.00 2,191.25 -0- 2010 13,088.00 3,272.00 $2,617.60 2011 15,178.00 3,794.50 3,035.60 2012 19,577.00 4,894.25 3,915.40 2013 17,069.00 4,267.25 -0