Opinion
18582-21
07-21-2023
ORDER AND DECISION
Albert G. Lauber Judge
On July 20, 2023, the Court issued its Opinion in this case (T.C. Memo. 2023-91), which states at the end thereof that "Decision will be entered for respondent with respect to the deficiencies and the penalty for 2013, and for petitioner with respect to the penalty for 2017." In consideration of the foregoing, it is
ORDERED AND DECIDED that there are deficiencies in income tax due from petitioner for the 2013 and 2017 tax years in the amounts of $12,310 and $1,572,391, respectively;
There is a penalty due from petitioner for the 2013 tax year, under the provisions of I.R.C. § 6662, in the amount of $2,462; and
There is no penalty due from petitioner for the 2017 tax year.