Opinion
16798-22S
09-28-2023
LISA A. STRINGFELLOW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo, Chief Special Trial Judge.
To give effect to the basis of settlement reflected in the proposed stipulated decision, filed September 26, 2023, pursuant to the stipulations filed in this case, and incorporating herein the facts stipulated as the findings of the Court, it is
ORDERED that the proposed stipulated decision is recharacterized and treated as a stipulation of settlement. It is further
ORDERED and DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2018 in the amount of $913.00, and that there is an overpayment in income tax for the taxable year 2018 in the amount of $3,225.00, which amount was paid on April 15, 2019, and for which amount a claim for refund could have been filed, under the provisions of I.R.C. § 6512(b)(3)(B), on April 11, 2022, the date of the mailing of the notice of deficiency;
That there is no addition to tax pursuant under I.R.C. § 6651 (a)(I) due from petitioner for taxable year 2018;
That there is no addition to tax pursuant under I.R.C. § 665l(a)(2) due from petitioner for taxable year 2018; and
That there is no addition to tax pursuant under I.R.C. § 6654(a) due from petitioner for taxable year 2018.