Opinion
6384-20
02-02-2023
JAMES M. ASKEW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On January 30, 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, upon review of that filing, the Court notes that the proposed decision document improperly refers to the additions to tax at issue in this case as "penalties."
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 2016 in the amount of $274,832.00;
That there is an addition to tax due from petitioner for the taxable year 2016 in the amount of $61,837.20 under the provisions of I.R.C. section 6651(a)(1);
That there is an addition to tax due from petitioner for the taxable year 2016 in the amount of $52,218.08 under the provisions of I.R.C. section 6651(a)(2); and
That there is an addition to tax due from petitioner for the taxable year 2016 in the amount of $6,569.56 under the provisions of I.R.C. section 6654.