UNITED STATES TAX COURT
NNABUGWU C. EZE,
Petitioner,
vs.
COMMISSIONER OF INTERNAL
REVENUE,
Respondent
Docket No.: 21425—19
OBJECTION TO THE RESPONDENT’S COMPUTATION FOR ENTRY OF DECISION
Petitioner files this objection to the Respondent’s Computation for Entry of Decision that
was filed on or about October 3, 2022. Petitioner raises this objection on the grounds that the
Respondent did not remove $2,847 and $1,050 from the computation. In the opinion, the judge
awarded the Petitioner the 2016 mortgage interest and was unclear about a discrepancy of $1,050
on the Notice of Deficiency and the amount claimed on Petitioner’s tax return. The IRS counsel
could not explain the difference, because it was a flat denial. In support of this objection,
Petitioner states as follows:
- Tax Court Rule 155(b) provides if the parties are not in agreement as to the
amount to be included in the decision, either party may challenge and/or object to the
computation presented by the other party. - Further, under Tax Court Rule 155(c), any argument challenging proposed
computations is “confined strictly to consideration of the correct computation of the amount to
be included in the decision resulting from the findings and conclusions made by the Court….”
See Vento v. Comm’r, 152 T.C. 1, 8 (2019) (quoting Molasky v. Comm’r, 91 T.C. 683, 685
(1988), aff’d, 897 F.2d 334 (8th Cir. 1990)).
- Here, the Petitioner challenges the Respondent’s computation because the
Respondent failed to remove certain amounts. Notably, in the judge gave Petitioner the 2016
mortgage interest in the amount of $2847. Further, the Respondent and Judge were unclear about
a discrepancy of $1,050. The said discrepancy is evident in the difference between the tax return
expense totaling $12,501 ($2,927- cell phone expenses & $9,574- professional education
expenses), and the amount the IRS disallowed on the Notice of Deficiency for this same expense
amounting to $11,451. - Because it was a flat denial the IRS counsel could not explain the difference, and
could not explain why the $1,050 was allowed. - There is therefore no reason why the Respondent should fail to deduct the said
$2847 and $1,050 from the computation.
WHEREFORE, the Petitioner prays this Honorable Court disregards and dismisses the
Respondent’s Computation. Alternatively, Petitioner prays this Honorable Court to issue an
Order compelling the Respondent to deduct $2847 and $1,050 from the computation. Petitioner
prays for any other order this Court deems just.
DATED: _______
Respectfully submitted,
NNABUGWU C. EZE
(443) 316-1334
Petitioner, Pro Se
CERTIFICATE OF SERVICE
I hereby certify that on [ENTER DATE], a copy of the foregoing Objection has been
filed in this Court and a copy thereof sent to the Respondent in the following address:
[ENTER ADDRESS FOR RESPONDENT].
NNABUGWU C. EZE
(443) 316-1334
Petitioner, Pro Se
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