Opinion
22401-18
10-15-2021
Gloria Ononuju Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Albert G. Lauber Judge
On July 26, 2021, the Court issued its Opinion in this case (T.C. Memo. 2021-94), which stated at the end thereof that "Decision will be entered under Rule 155." By order served July 27, 2021, we directed the parties to file computations for entry of decision by September 30, 2021. Respondent timely filed his computations for entry of decision. Petitioner filed no computations and has expressed no disagreement with respondent's computations.
Upon due consideration, it is
ORDERED AND DECIDED that, under the provisions of I.R.C. sec. 4958(a)(1), there is a deficiency in excise tax due from petitioner for the 2014 tax year in the amount of $28,750.00;
That, under the provisions of I.R.C. sec. 4958(b), there is a deficiency in excise tax due from petitioner for the 2014 tax year in the amount of $230,000;
That, under the provisions of I.R.C. sec. 6651(a)(1), there is an addition to tax due from petitioner for the 2014 tax year in the amount of $6,468.75;
That, under the provisions of I.R.C. sec. 6651(a)(2), there is an addition to tax due from petitioner for the 2014 tax year in the amount of $7,187.50.