Opinion
28445-21
10-31-2022
EVERADO GODOY JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Emin Toro Judge
This case is currently calendared for trial during the Court's January 17, 2023, Los Angeles, California, trial session. On October 24, 2022, the parties filed a Proposed Stipulated Decision (Doc. 8). However, upon review of the Proposed Stipulated Decision, the Court notes that the name of petitioner in the caption does not match the caption of this case. 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. 8) filed October 24, 2022, is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there is no deficiency in income tax due from, nor overpayment due to, the petitioner for the taxable year 2018; and
That there is no penalty due from petitioner for the taxable year 2018 under the provisions of I.R.C. § 6662(a).