Opinion
21593-22S
02-26-2024
THOMAS MICHAEL BIDEGARY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Jennifer E. Siegel Special Trial Judge
On February 12, 2024, the parties submitted a Proposed Stipulated Decision signed by petitioner on December 22, 2023. On February 23, 2024, the Court held a conference call with the parties to discuss the document and an apparent error in one of the calculations. Based on their representations and respondent's concession of the 2016 §6651(a)(1) addition to tax during that call, it is
ORDERED that the Proposed Stipulated Decision is recharacterized as the parties' Report. It is further
ORDERED that, reflecting respondent's concession, the parties shall, on or before March 1, 2024, show cause in writing why the Court should not enter a decision in this case reflecting that there is a deficiency in federal income tax due from petitioner for 2016 of $244.00 and an addition to tax pursuant to §6651(a)(2) due for that same year of $61.00, that there is no §6651(a)(1) addition to tax due for 2016, and that there is no deficiency or addition to tax due from petitioner for 2017.