Opinion
12930-18
03-08-2022
ORDER AND DECISION
Cary Douglas Pugh, Judge
Pursuant to the determination of the Court as set forth in 158 T.C. No. 3, filed March 3, 2022, and upon due consideration and for cause, it is hereby
ORDERED that petitioner's Motion for Reasonable Litigation or Administrative Costs, filed February 22, 2021, is denied. It is further
ORDERED that respondent's Motion for Entry of Decision, filed, December 28, 2021, is granted. It is further
ORDERED AND DECIDED that there are deficiencies in income tax and penalties due from petitioner before application of I.R.C. § 6015(c) as follows:
Penalties I.R.C.
Year
Deficiency
§ 6663
§ 6662
2008
$53,981.00
None
§10, 796.20
2009
$24,075.00
None
$4,815.00
2010
$25,050.00
None
$5,010.00
It is further
ORDERED AND DECIDED that the following deficiencies in income tax and penalties are due from petitioner, after application of I.R.C. § 6015(c):
Penalties I.R.C.
Year
Deficiency
§ 6663
§ 6662
2008
None
None
None
2009
None
None
None
2010
None
None
None
It is further
ORDERED AND DECIDED that there are no overpayments in income tax due to petitioner for the taxable years 2008, 2009, and 2010.