Opinion
10756-23
02-28-2024
CLARK SCOTT & KELLY SCOTT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
On February 27, 2024, the parties filed a Proposed Stipulated Decision. The Proposed Stipulated Decision refers to petitioners as "petitioner." The Court is therefore unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing and to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed February 27, 2024, is recharacterized and treated as the parties' Stipulation of Settlement. 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 petitioners for the taxable year 2018 in the amount of $40,908.00; and
That there is a penalty due from petitioners for the taxable year 2018 in the amount of $4,772.40 under the provisions of I.R.C. § 6662(a).