Opinion
18833-21S
07-11-2022
JOSHUA R. DEERING & SASHA S. DEERING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
For the reasons set forth in the Court's oral findings of fact and opinion, rendered on June 8, 2022, it is
ORDERED that petitioner's motion for summary judgment, filed April 3, 2022, is denied. It is further
ORDERED that respondent's motion to impose a penalty, filed May 16, 2022, is denied. It is further
ORDERED and DECIDED that for 2017, there is a $5,144 deficiency in petitioners' Federal income tax, and petitioners are not liable for an I.R.C. Section 6662(a) penalty.