Opinion
18106-22
08-22-2023
MARIA ISABEL ZOTEA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge.
On August 17, 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, upon review thereof, the Court notes that the proposed decision document includes typographical errors and improperly refers to the I.R.C. section 6651(a)(1) addition to tax determined in the notice of deficiency as a "penalty." Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2020 in the amount of $6,615.00;
That there is no addition to tax under I.R.C. section 6651(a)(1) due from petitioner for the taxable year 2020;
That there is no penalty under I.R.C. section 6662(a) due from petitioner for the taxable year 2020; and
That there is no penalty under I.R.C. section 6676 due from petitioner for the taxable year 2020.