Opinion
6884-23S
10-30-2023
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
Because of the manner in which the proposed stipulated decision, filed October 27, 2023, was prepared and submitted, it is
ORDERED that the document is recharacterized and treated as stipulation of settlement. To reflect the basis of settlement agreed upon between the parties as reflected in that document, it is
ORDERED and DECIDED: That for 2020, there is no deficiency in petitioner's federal income tax, petitioner is not liable for an I.R.C. §6662(a) penalty, and petitioner's federal income tax has not been overpaid.