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In this case, respondent has moved for entry of decision.
The Court will grant the motion. As a result of the Court’s
ruling of March 23, 2005, it was established that petitioner
received $51,114 as income. See Swain v. Commissioner, 118 T.C.
358, 362 (2002). On April 6, 2005, respondent conceded the
remaining issues relating to the cancellation of indebtedness
income and the section 6662(a) penalty. There are no issues
remaining. Accordingly, petitioner received $51,114 of taxable
income in 2002, had no cancellation of indebtedness income, and
is not liable for a section 6662(a) penalty.
Therefore, we shall enter a decision for respondent with
respect to the deficiency adjusted for respondent’s concessions.
Petitioner is liable for a tax deficiency of $8,071 for tax year
2002 with no section 6662(a) penalty.
In reaching our holding, we have considered all arguments
made and conclude that any arguments not mentioned above are
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011