Opinion
7964-19
04-01-2024
LANCE C. STANDIFIRD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Travis A. Greaves Judge
On March 14, 2024, the Court issued a Memorandum Opinion (T.C. Memo. 2024-30) in this case. Pursuant to that Memorandum Opinion, and taking into account the concessions of the parties, it is
ORDERED that the portion of this case concerning the computational adjustments to income tax and self-employment tax deficiencies resulting from the partnership-level proceeding is dismissed for lack of jurisdiction. It is further
ORDERED that respondent's Motion for Summary Judgment is granted in part, in that petitioner is liable for additions to tax under sections 6651(f) and 6654 in the amounts shown on Form 5278, dated February 23, 2023. It is further
ORDERED that respondent's Motion for Summary Judgment is denied in part, insofar as it seeks to impose additions to tax under section 6651(a)(2) that are not properly before the Court. It is further
ORDERED that the parties shall, on or before May 1, 2024, file computations for entry of decision under Rule 155, Tax Court Rules of Practice and Procedure, for petitioner's income tax deficiencies as they relate to his concessions of the interest and dividend income.