Opinion
15201-23S
07-29-2024
DEONTAE PETTIGREW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On March 28, 2024, the parties filed a Proposed Stipulated Decision. By Order served April 2, 2024, the Court deemed stricken that filing on the ground that the proposed decision document referenced a penalty determination for the taxable year 2021 that did not appear to be at issue in this case. The Order further directed that the parties file a revised proposed stipulated decision on or before May 3, 2024.
On June 3, 2024, respondent filed a Motion for Entry of Decision, attaching thereto a proposed decision document that is identical to that previously filed by the parties on March 28, 2024, but for the erroneous reference to a penalty determination for 2021. By Order served June 4, 2024, the Court directed petitioner to file an objection, if any, to the Motion on or before June 25, 2024. The Order informed petitioner that failure to file such an objection by the foregoing date could result in the granting of the Motion and entry of decision in accordance with the attached proposed decision document. To date, no such objection has been filed.
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced Motion is granted in that it is:
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2020 in the amount of $5,566.00;
That there is a deficiency in income tax due from petitioner for the taxable year 2021 in the amount of $27,735.00; and
That there is a penalty under I.R.C. section 6662(a) due from petitioner for the taxable year 2020 in the amount of $1,113.20.