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Arnold v. Comm'r of Internal Revenue

United States Tax Court
Aug 31, 2023
No. 8354-22 (U.S.T.C. Aug. 31, 2023)

Opinion

8354-22

08-31-2023

ROBERT E. ARNOLD, III & ANDREA L. ARNOLD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER AND DECISION

KATHLEEN KERRIGAN CHIEF JUDGE.

On August 30, 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 6662(a) accuracy-related penalties determined in the Notice of Deficiency as "additions to tax." 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 petitioners for the taxable year 2015 in the amount of $7,898.00;

That there is no deficiency in income tax due from, nor overpayment due to, petitioners for the taxable year 2016;

That there is an addition to tax under I.R.C. section 6651(a)(1) due from petitioners for the taxable year 2015 in the amount of $112.95; and

That there are no penalties under I.R.C. section 6662(a) due from petitioners for the taxable years 2015 and 2016.


Summaries of

Arnold v. Comm'r of Internal Revenue

United States Tax Court
Aug 31, 2023
No. 8354-22 (U.S.T.C. Aug. 31, 2023)
Case details for

Arnold v. Comm'r of Internal Revenue

Case Details

Full title:ROBERT E. ARNOLD, III & ANDREA L. ARNOLD, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Aug 31, 2023

Citations

No. 8354-22 (U.S.T.C. Aug. 31, 2023)