Opinion
31743-21S
03-06-2023
PHUONG H. PHAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge.
Pursuant to Rule 152(b), Tax Court Rules of Practice and Procedure, it is
ORDERED that the Clerk of the Court shall transmit herewith to petitioner and to respondent a copy of the pages of the transcript of the remote trial in the above case before Special Trial Judge Diana L. Leyden at San Diego, California, on February 1, 2023, containing her oral findings of fact and opinion rendered at the trial session at which the case was heard.
In accordance with the oral findings of fact and opinion, a decision will be entered for respondent as to the deficiency and for petitioner as to the accuracy-related penalty under section 6662(a).