Opinion
3829-23
08-15-2023
ESTATE OF DAWN ELLICE FRNKA, DECEASED, BRETT EDWARD DESHAZO, INDEPENDENT EXECUTOR, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
For cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed August 14, 2023, is recharacterized as a Stipulation of Settlement. In order to give effect to the basis of settlement reflected in that document, it is further
ORDERED AND DECIDED that there is no deficiency in income tax due from, and no overpayment due to, petitioner(s) for the taxable year 2020; and
That there is no penalty due from petitioner(s) for the taxable year 2020 under the provisions of I.R.C. section 6662(a).