Opinion
14507-19
09-29-2021
Ben Taverniti, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER OF DISMISSAL AND DECISION
KATHLEEN KERRIGAN JUDGE
This case was called from the calendar for the remote trial session of the Court at Denver, Colorado on September 28, 2021, for hearing on respondent's motion to dismiss for lack of prosecution, filed January 8, 2021. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the Court's Order to show cause, served April 13, 2021, is made absolute. It is further
ORDERED that respondent's motion, filed January 8, 2021, is granted. It is further
ORDERED and DECIDED that there are deficiencies and penalties/additions to tax due from petitioner as follows:
|
Additions to Tax/Penalties I.R.C. §§ | ||||
| Year | Deficiency | 6651(a)(1) | 6651(a)(2) | 6654(a) |
| 2014 | $292, 864.00 | $59, 676.53 | * | $4, 707.55 |
| 2015 | $674, 343.00 | $151, 727.18 | * | $12, 145.06 |
| 2016 | $722, 912.00 | $162, 655.20 | * | $17, 280.74 |
* That there are additions to tax due from petitioner for the taxable years 2014, 2015, and 2016, under the provisions of I.R.C. § 6651(a)(2), of 0.5% of the amounts of $292, 864.00, $674, 343.00, and $722, 912.00, respectively, commencing on the due dates of each of petitioner's respective income tax returns and accruing for each month or fraction thereof during which petitioner fails to pay, not exceeding 25% in the aggregate.