Opinion
8805-18
08-13-2021
Christian D. Silver Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Elizabeth A. Copeland Judge
Pursuant to the Court's Opinion (T.C. Memo. 2021-98) issued in the above docketed case on August 9, 2021, it is
ORDERED and DECIDED that there is a deficiency in income tax in the amount of $3, 640.00 due from petitioner for tax year 2012. It is further
ORDERED and DECIDED that there is no addition to tax due from petitioner for tax year 2012 under the provisions of I.R.C. § 6651(a)(2). It is further
ORDERED and DECIDED that there is no penalty due from petitioner for tax year 2012 under the provisions of I.R.C. § 6662(a). It is further
ORDERED and DECIDED that respondent's oral motion for a penalty under the provisions of I.R.C. § 6673 is denied.