Opinion
15837-21S
03-16-2022
JOHN F. ARVAY & KELLE S. ARVAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy, Special Trial Judge
On March 15, 2022, the parties filed a Proposed Stipulated Decision. The Proposed Stipulated Decision fails to reference petitioners, in the plural sense, and improperly attached a Statement of Account (Form 3623). 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, filed March 15, 2022, is recharacterized and treated as the parties' Settlement Stipulation. It is further
ORDERED and DECIDED that there is a deficiency in income tax due from petitioners for the taxable year 2017 in the amount of $6,598.00; and
That there is a penalty due from petitioners for taxable year 2017, under the provisions of I.R.C. § 6662(a), in the amount of $1,319.60.