Opinion
14344-21
07-26-2022
GARY J. BURKE & SALLY M. BURKE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
On July 25, 2022, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, upon review thereof, the Court notes that the caption on the proposed decision document is incorrect, insofar as the docket number includes an "S." Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, 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 $83,182.00; and
That there is a penalty under I.R.C. section 6662(a) due from petitioners for the taxable year 2017 in the amount of $16,636.00.