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IRS Answers Petition Challenging Deficiency, Penalty

DEC. 2, 2022

W G Wade Shows Inc. v. Commissioner

DATED DEC. 2, 2022
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W G Wade Shows Inc. v. Commissioner

W. G. WADE SHOWS, INC.,
Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent.

UNITED STATES TAX COURT

ANSWER

RESPONDENT, in answer to the petition filed in the above-entitled case and without the benefit of the administrative file, admits, denies, and alleges as follows:

1. Admits.

2. Admits.

3. Admits that respondent proposed deficiencies in tax in its Notice of Deficiency.

a. Admits the tax year in question is 2018 and admits that the tax amount in contention is $190,629.00.

b. Admits that the proposed penalties are accuracy related, that they were proposed under I.R.C. § 6662(a), and that the penalty amount in contention is $38,125.80.

4. Denies all in paragraph 4 for a lack of sufficient knowledge or information.

a. Denies all in sub-paragraph 4a for a lack of sufficient knowledge or information.

b. Denies all in sub-paragraph 4b for a lack of sufficient knowledge or information.

5. Denies all in paragraph 5 for a lack of sufficient knowledge or information.

a. Denies all in sub-paragraph 5a for a lack of sufficient knowledge or information.

b. Denies all in sub-paragraph 5b for a lack of sufficient knowledge or information.

6. Denies, generally, every allegation of the petition not specifically admitted, qualified, or denied herein.

WHEREFORE, respondent prays that the relief sought in the petition be denied and that respondent's determination, as set forth in the notice of deficiency, be approved in all respects.

DRITA TONUZI
Deputy Chief Counsel (Operations)
Internal Revenue Service

Date: December 2, 2022

PETER J. MANCINI
Attorney
(Small Business/Self Employed)
Tax Court Bar No. MP0518
985 Michigan Avenue
Suite #907, Mail Stop 31
Detroit, MI 48226
Telephone: (313) 234-2500
peter.j.mancini@irscounsel.treas.gov

OF COUNSEL:
JOSEPH W. SPIRES
Division Counsel (SB/SE)
(Small Business/Self Employed)
ELKE E. FRANKLIN
Area Counsel
(Small Business/Self Employed: Area 4)
REBECCA M. CLARK
Associate Area Counsel
(Small Business/Self Employed)

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