Opinion
5656-23S
11-29-2023
STEPHEN K. CUNNINGHAM, JR., & MEGHANN R. CUNNINGHAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy, Special Trial Judge.
On November 22, 2023, the parties filed a Proposed Stipulated Decision and Settlement Stipulation. The caption on the Proposed Stipulated Decision contains an error. 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, it is hereby
ORDERED that the parties' Proposed Stipulated Decision (Doc. 9) is recharacterized and treated as the parties' Supplement to Settlement Stipulation. It is further
ORDERED AND DECIDED: That there is a deficiency in income tax due from petitioners for the taxable year 2020 in the amount of $7,403.00, and that there is an overpayment in income tax due to petitioners for the taxable year 2020 in the amount of $911.00, which amount was paid after the mailing of the notice of deficiency; and
That there is no penalty due from petitioners for the taxable year 2020, under the provisions of I.R.C. § 6662(a).