Opinion
19160-19S
07-19-2022
JAMES FORREST WILLETTS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge.
Pursuant to the determination of the Court, as set forth in its Summary Opinion (T.C. Summ. Op. 2021-39), filed November 22, 2021, it is
ORDERED AND DECIDED: That there is a deficiency in income tax for petitioner for taxable year 2014 in the amount of $13,545.00 and that there is an overpayment in income tax for taxable year 2014 in the amount of $1,553.00, which amount was paid on April 15, 2015, and for which amount a claim for refund was filed on May 2, 2018, which was within the period provided by I.R.C. § 6511(b)(2), and which claim had not been disallowed before the date of the mailing of the notice of deficiency.
That there is no addition to tax under I.R.C. § 6651(a)(1) due from petitioner for taxable year 2014; and
That there is no addition to tax under I.R.C. § 6651(a)(2) due from petitioner for taxable year 2014.