Opinion
11874-20
02-02-2023
ORDER AND DECISION
Emin Toro, Judge.
On January 25, 2023, the parties filed a Proposed Stipulated Decision (Doc. 32) that refers to a Settlement Stipulation. After reviewing the record in this case, the Court notes that the parties failed to file a Settlement Stipulation.
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. 32) filed January 25, 2023, is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there is no deficiency in income tax due from, nor overpayment due to, petitioners for the taxable years 2016 or 2017; and
That there is no penalty due from petitioners for the taxable years 2016 or 2017 under the provisions of I.R.C. § 6662(a); and
That there is no addition to tax due from petitioners for the taxable year 2017 under the provisions of I.R.C. § 6651(a)(1).