Opinion
4242-23S
05-15-2024
ROY ACOSTA & VERONICA ACOSTA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
Because the Proposed Stipulated Decision, filed May 14, 2024, does not address the determination of the I.R.C. section 6662(a) penalty made in the Notice of Deficiency (a copy of which is attached to the Petition), it is
ORDERED that the document is recharacterized and treated as a stipulation of settled issues.