Opinion
21360-22
06-28-2024
CRAIG E. REESE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Tamara W. Ashford, Judge
This case was calendared for trial at the Session of the Court commencing on April 22, 2024, in Las Vegas, Nevada. On April 22, 2024, when the case was called from the calendar and then recalled that same day, petitioner and counsel for respondent appeared and were heard; at the recall, the parties represented to the Court that they had reached a basis for settlement that resolves all issues in the case, and counsel for respondent stated the terms of the settlement for the record. The next day, on April 23, 2024, the parties filed a Stipulation of Settled Issues that memorialized the terms of the settlement. By Order served on the parties on April 24, 2024, the undersigned Judge ordered the parties, on or before June 24, 2024, to submit to the Court an agreed stipulated decision document or file status reports, separately or jointly, apprising the Court of the then present status of the case.
On June 21, 2024, respondent filed a Motion for Entry of Decision, requesting that the Court enter a decision in this case pursuant to the agreement and stipulation of the parties and in accordance with an unsigned proposed decision document (which respondent attached to the motion) reflecting that for the 2018 taxable year (1) there is a reduced deficiency in income tax due from petitioner in the amount of $8,359.00 and (2) there are reduced additions to tax due from petitioner under I.R.C. sections 6651(a)(1) and (a)(2) and 6654, in the amounts of $1,880.78, $2,089.75, and $266.03. In his motion respondent states that computations were prepared and on May 15, 2024, those computations, together with a proposed decision document, were mailed to petitioner. Respondent also states that the letter accompanying those documents requested that petitioner execute the proposed decision document and return it by June 15, 2024. Respondent further states that on June 18, 2024, he emailed petitioner regarding the decision document, but petitioner replied to the email generally, not providing any details as to when the document would be returned. Upon due consideration and for cause, it is hereby
ORDERED that respondent's Motion for Entry of Decision, filed June 21, 2024, is granted. It is further
ORDERED and DECIDED that there is a deficiency in income tax due from petitioner for the 2018 taxable year in the amount of $8,359.00. It is further
ORDERED and DECIDED that there is an addition to tax due from petitioner under I.R.C. section 6651(a)(1) for the 2018 taxable year in the amount of $1,880.78. It is further
ORDERED and DECIDED that there is an addition to tax due from petitioner under I.R.C. section 6651(a)(2) for the 2018 taxable year in the amount of $2,089.75. It is further
ORDERED and DECIDED that there is an addition to tax due from petitioner under I.R.C. section 6654 for the 2018 taxable year in the amount of $266.03.