Opinion
21604-18
07-11-2022
David Gilmartin, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER AND DECISION
Juan F. Vasquez Judge
Pursuant to the determination of the Court, as set forth in its opinion filed June 23, 2022, it is
ORDERED that respondent's oral motion to impose sanctions under I.R.C. § 6673(a)(1), dated January 30, 2020, is granted. It is further
ORDERED and DECIDED that there are deficiencies in income tax due from petitioner and that petitioner is liable for additions to tax under I.R.C. §§ 6651(f), 6651(a)(2), and 6654 in the following years and amounts:
| Year | Deficiency | Additions to tax | ||
| § 6651(f) § | 6651(a)(2) | § 6654 | ||
| 1997 | $33,163.00 | $24,043.18 | $8,290.75 | $1,763.53 |
| 1998 | 9,971.00 | 7,228.98 | 2,492.75 | 452.59 |
| 1999 | 34,586.00 | 25,074.85 | 8,646.50 | 1,661.08 |
| 2000 | 43,357.00 | 31,433.83 | 10,839.25 | 2,331.92 |
| 2001 | 31,173.00 | 22,600.43 | 7,793.25 | 1,245.79 |
| 2002 | 13,779.00 | 9,989.78 | 3,444.75 | 460.45 |
| 2004 | 10,095.00 | 1,565.28 | 539.75 | -0- |
| 2005 | 36,599.00 | 24,060.58 | 8,296.75 | 1,315.95 |
| 2006 | 3,448.00 | 898.28 | 309.75 | -0- |
| 2008 | 21,831.00 | 2,201.10 | 759.00 | -0- |
| 2009 | 26,797.00 | 4,183.97 | 1,442.75 | -0- |
| 2010 | 24,363.00 | 3,675.03 | 1,267.25 | -0- |
That there are damages due from petitioner, which are hereby awarded to the United States, in the amount of $5,000 pursuant to I.R.C. § 6673(a)(1).