Opinion
15711-17
09-10-2021
CHARLES T. PHILLIPS, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER AND DECISION
Richard T. Morrison, Judge
On October 7, 2020, the parties filed a stipulation of settled issues. The stipulation of settled issues (1) stated the terms upon which the case had settled and (2) represented that these terms constituted the "settlement of all of the issues in the above-entitled case".
On October 21, 2020, respondent notified the Court that respondent had not yet received the signed proposed decision document, which was sent to petitioner on September 24, 2020. Respondent further advised that respondent was unable to reach petitioner.
On November 12, 2020, the Court ordered the parties to file Rule 155 computations on or before February 12, 2021.
On February 12, 2021, respondent filed Rule 155 computations.
Having received no Rule 155 computations from petitioner, on April 13, 2021, the Court ordered petitioner to file a response to respondent's Rule 155 computations, on or before June 14, 2021.
As of the date of this Order and Decision, no response has been received by or on behalf of petitioner.
Upon due consideration of the foregoing, it is
ORDERED AND DECIDED that there are deficiencies in income tax due from petitioner for the taxable years 2011, 2014, and 2015, in the amounts of $39, 224.00, $1, 311.00, and $7, 831.00, respectively; and
That there are additions to tax due from petitioner for the taxable years 2011, 2014, and 2015, under I.R.C. section 6651(a)(1), in the amounts of $8, 825.40, $294.98, and $1, 761.98, respectively; and
That there are additions to tax due from petitioner for the taxable years 2011, 2014, and 2015, under I.R.C. section 6651(a)(2) in the amounts of $9, 806.00, $327.75, and $1, 957.75, respectively.
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