Opinion
8354-22
08-31-2023
ROBERT E. ARNOLD, III & ANDREA L. ARNOLD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
KATHLEEN KERRIGAN CHIEF JUDGE.
On August 30, 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, the Court notes that the proposed decision document improperly refers to the I.R.C. section 6662(a) accuracy-related penalties determined in the Notice of Deficiency as "additions to tax." 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 petitioners for the taxable year 2015 in the amount of $7,898.00;
That there is no deficiency in income tax due from, nor overpayment due to, petitioners for the taxable year 2016;
That there is an addition to tax under I.R.C. section 6651(a)(1) due from petitioners for the taxable year 2015 in the amount of $112.95; and
That there are no penalties under I.R.C. section 6662(a) due from petitioners for the taxable years 2015 and 2016.