Opinion
3020-14
07-11-2023
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
Pursuant to the determination of the Court as set forth in its Memorandum Opinion (T.C. Memo. 2023-70), filed June 13, 2023, and the parties' joint Stipulation of Settled Issues, filed December 20, 2018, it is
ORDERED that petitioner's Motion for Reasonable Litigation or Administrative Costs, filed January 18, 2019, is denied. It is further
ORDERED AND DECIDED that there are no deficiencies in income tax due from, nor overpayments due to, petitioner for the taxable years 2008, 2009, and 2011;
That there are no additions to tax due from petitioner for the taxable years 2008, 2009, and 2011, under the provisions of I.R.C. §§ 6651(a)(1) or 6651(a)(2); and
That there are no additions to tax due from petitioner for the taxable years 2009 and 2011, under the provisions of I.R.C. § 6654.