Opinion
13348-21
08-15-2023
MICHAEL J. GOLDEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Albert G. Lauber Judge
Pursuant to the Court's Opinion (T.C. Memo. 2023-103) issued in the above-docketed case on August 10, 2023, it is
ORDERED that respondent's Motion for Summary Judgment filed February 16, 2023, is granted. It is further
ORDERED that petitioner's Cross-Motion for Summary Judgment filed March 19, 2023, is denied. It is further
ORDERED AND DECIDED that there is no deficiency in income tax due from, nor overpayment due to, petitioner for the taxable year 2015; and there are no additions to tax due from petitioner for the taxable year 2015 under the provisions of I.R.C. § 6651(a)(1) or (a)(2).