Opinion
7319-18
11-02-2022
JOSEPH A. AZIZI & ROYA A. RAZI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
EMIN TORO, JUDGE.
On October 27, 2022, the parties filed a Proposed Stipulated Decision (Doc. 62). However, upon review of the Proposed Stipulated Decision, the Court notes that the name of one of the petitioners in the caption does not match the caption of this case. 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 (Doc. 62) filed October 27, 2022, is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there are deficiencies in income tax due from petitioners for the taxable years 2012, 2013, and 2014 in the amounts of $103,461.00, $53,562.00, and $4,632.00 respectively; and
That there are penalties due from petitioners for the taxable years 2012, 2013, and 2014 under the provisions of I.R.C. §6662(a) in the amounts of $15,519.15, $8,034.30, and $694.80, respectively.