Opinion
14410-15
09-06-2022
JOHANNES LAMPRECHT & LINDA LAMPRECHT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
David Gustafson, Judge.
Pursuant to the determination of the Court set forth in its Memorandum Opinion (T.C. Memo. 2022-91) filed August 31, 2022 (Doc. 181), sustaining respondent's notice of deficiency dated January 9, 2015, it is
ORDERED that respondent's motion for summary judgment filed February 12, 2021 (Doc. 158), is granted. It is further
ORDERED that petitioner's motion for summary judgment filed April 6, 2021 (Doc. 173), is denied. It is further
DECIDED that there are penalties due from petitioners under section 6662 for tax year 2006 in the amount of $124,294.20 and for tax year 2007 in the amount of $376,448.60.