Opinion
4803-15
06-28-2022
ORDER AND DECISION
Joseph Robert Goeke, Judge.
On April 1, 2022, respondent filed a Status Report with an attached proposed decision document which petitioner declined to execute on the basis of petitioner's arguments in a Motion for Reconsideration of a denial of administrative and litigation costs, which we denied by Order, served April 12, 2022. In that Order, we directed petitioner to file a response.
Petitioner has not filed a proposed decision document. In the Response to Status Report filed May 11, 2022, petitioner contends that there is no tax deficiency. He argues that our decision in our Memorandum Opinion, T.C. Memo. 2020-71, that transfers after 1989 were gifts is erroneous. Petitioner also continues to seek an award for costs arguing that he made a qualified offer of $25,000.
We have previously considered and rejected petitioner's arguments. Accordingly, we will enter a Decision on the basis of respondent's proposed decision document. Upon due consideration, it is
ORDERED and DECIDED that there is a deficiency in estate tax due from petitioner in the amount of $38,061.00.