Opinion
32263-21S
09-27-2022
GEORGE C. COTSONAS & JANE M. COTSONAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge.
Pursuant to the settlement stipulation, filed September 23, 2022, and incorporating the facts recited in that document as the findings of the Court, and because the proposed stipulated decision, also filed September 23, 2022, is not in a format that would allow the Court to give effect to its intent, it is
ORDERED that the proposed stipulated decision is stricken. It is further
ORDERED and DECIDED: That there is no deficiency in income tax due from the petitioners for taxable year 2018, and that there is an overpayment in income tax due to petitioners for taxable year 2018 in the amount of $15,186.05, which amount was paid on February 28, 2022, which was after the mailing date of the notice of deficiency; and
That there is no penalty due from the petitioners for the taxable year 2018 under the provisions of I.R.C. §6662(a).