Opinion
16958-18L
07-07-2022
CHULE RAIN WALKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Joseph W. Nega Judge
Pursuant to the findings of the Court in its Memorandum Opinion (T.C. Memo. 2022-63) filed June 15, 2022, it is
ORDERED AND DECIDED that so much of the determinations set forth in the Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, dated July 26, 2018, upon which this case is based, as relates to the I.R.C. section 6702(a) penalty assessed against petitioner for filing his original Form 1040, is sustained. It is further
ORDERED AND DECIDED that so much of the determinations set forth in the Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, dated July 26, 2018, upon which this case is based, as relates to the I.R.C. section 6702(a) penalty assessed against petitioner for submitting a copy of his original Form 1040 by letter dated November 8, 2016, is not sustained.