Opinion
485-15
10-12-2021
Monty Ervin, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER AND DECISION
ALBERT G. LAUBER JUDGE.
On June 23, 2021, the Court issued its Opinion in this case (T.C. Memo. 2021-75), which stated at the end thereof that "decision will be entered under Rule 155." By order served June 24, 2021, we directed the parties to file computations for entry of decision by August 23, 2021. Respondent timely filed his computations for entry of decision. Petitioner filed no computations and has expressed no disagreement with respondent's computations.
On August 20, 2021, respondent filed a Motion for Entry of Decision with a proposed decision document. Respondent represents that he attempted to discuss the computations with petitioner's counsel but that had been unsuccessful in reaching him. By order served August 27, 2021, we directed petitioner to respond to the Motion by September 17, 2021. We advised petitioner that if he did not respond, we would "grant respondent's Motion and enter a decision consistent with respondent's computations." Petitioner did not file a response by September 17 or subsequently.
Upon due consideration, it is
ORDERED that respondent's Motion for Entry of Decision, filed August 20, 2021, is granted. It is further
ORDERED AND DECIDED that there are deficiencies in income tax and additions to tax due from petitioner as follows:
| Year | Deficiency | Sec. 6651(a)(1) | Sec. 6651(a)(2) | Sec. 6651(f) | Sec. 6654 |
| 2002 | $77, 955.00 | $17, 539.88 | $19, 488.75 | --- | $2, 605.05 |
| 2003 | 100, 041.00 | 22, 509.23 | 25, 010.25 | --- | 2, 581.16 |
| 2004 | 103, 659.00 | --- | 25, 914.75 | $75, 152.77 | --- |
| 2005 | 75, 048.00 | --- | 18, 762.00 | 54, 409.80 | --- |
| 2006 | 113, 630.00 | --- | 28, 407.50 | 82, 381.75 | --- |
| 2007 | 49, 545.00 | 11, 147.63 | 12, 386.25 | --- | 2, 254.93 |