Opinion
8029-21
09-14-2022
JOHN C. KELLER & APRIL R. KELLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
On August 8, 2022, respondent filed a motion for entry of decision. On August 11, 2022, the Court issued petitioners an Order to Show Cause why respondent's motion should not be granted. No response to the Court's Order has been filed. On September 13, 2022, the Court entered and Order and Decision that contained a typographical error. Premises considered, it is
ORDERED that the Court's Order and Decision, served September 13, 2022 is vacated and set aside. It is further
ORDERED that the Court's Order to Show Cause, served August 11, 2022, is made absolute. It is further
ORDERED that respondent's motion for entry of decision, filed August 8, 2022, is granted. It is further
ORDERED and DECIDED that there is a deficiency for the 2017 taxable year in the amount of $51,563.00 due from petitioners before the application of I.R.C. § 6015(b).
That after the application of I.R.C. § 6015(b) there is no deficiency for the 2017 taxable year due from petitioner April R. Keller;
That there is a penalty under I.R.C. § 6662(a) due from petitioners for taxable year 2017 in the amount of $5,156.30 before the application of I.R.C. § 6015(b);
That after the application of I.R.C. § 6015(b) there is no penalty for the 2017 taxable year due from petitioner April R. Keller.