Opinion
26324-22
09-05-2023
LINDA SUE SANDERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On September 1, 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, the Court notes that the proposed decision document improperly refers to the I.R.C. section 6654 addition to tax determined in the Notice of Deficiency as a "penalty." Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2018 in the amount of $28,119.00;
That there are additions to tax under I.R.C. sections 6651(a)(1) and 6651(a)(2) due from petitioner for the taxable year 2018 in the amounts of $2,877.52 and $3,133.30, respectively; and
That there is no addition to tax under I.R.C. section 6654 due from petitioner for the taxable year 2018.