Opinion
16364-23
04-11-2024
JOSH JOHNSRUD & EMILY JOHNSRUD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed April 9, 2024, and there being no objection to the granting of the Motion, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for failure to state a claim upon which relief can be granted. It is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioners for the taxable year 2021 in the amount of $9,629.00; and
That there is a penalty under I.R.C. section 6662(a) due from petitioners for the taxable year 2021 in the amount of $2,088.00.