Opinion
2528-22S
08-25-2023
TAYLOR M. KALEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge.
Because of the manner in which the caption of the Proposed Stipulated Decision, filed August 21, 2023, is shown, it is
ORDERED that the document is stricken. To give effect to the basis of settlement reflected in that document it is
ORDERED and DECIDED that for 2019, before the application of I.R.C. section 6015(c) there is a $17,287 deficiency in petitioner's federal income tax, and petitioner is liable for a $1,301 I.R.C. section 6662(a) penalty; and that after the application of I.R.C. section 6015(c), there is no deficiency in petitioner's federal income tax, petitioner is not liable for an I.R.C. section 6662(a) penalty, and petitioner's federal income tax has not been overpaid.