Tseytin v. Commissioner of Internal Revenue, 090618 FEDTAX, 354-12

Docket Nº:354-12
Opinion Judge:Joel Gerber, Judge.
Party Name:MICHAEL TSEYTIN & ELLA TSEYTIN, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Case Date:September 06, 2018
Court:United States Tax Court
 
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MICHAEL TSEYTIN & ELLA TSEYTIN, Petitioners,

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

No. 354-12

United States Tax Court

September 6, 2018

ORDER

Joel Gerber, Judge.

This case was submitted for decision without trial under Rule 122, Tax Court Rules of Practice and Procedure, on May 12, 2014. The parties stipulated that petitioner Ella Tseytin was entitled to full relief under I.R.C. section 6015(f) and that any deficiency and penalty would be assessed against petitioner Michael Tseytin only. The Court issued its Opinion (T.C. Memo. 2015-247), in this case on December 28, 2015, and it's Decision on December 29, 2015.

Due to an inadvertent clerical error in the preparation of the Decision, petitioner Ella Tseytin's name was included with petitioner Michael Tseytin's making her liable along with him for a deficiency and penalty for the 2007 taxable year. No motion to vacate or revise the Decision was filed by either party. Petitioners filed a Notice of Appeal from this Court's Decision with the United States Court of Appeals for the Third Circuit on March 22, 2016, with respect to Michael Tseytin's 2007 tax liabilities.

The Court of Appeals issued its Mandate on October 10, 2017. The Court of Appeals affirmed this Court's...

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