Opinion
13961-23
07-26-2024
JUAN MARTIN BUSTAMANTE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
The manner in which the Proposed Stipulated Decision, electronically submitted to the Court and filed July 25, 2024, does not allow for the document to be properly processed. That being so, it is
ORDERED that the document is recharacterized and treated as a stipulation of settlement. To give effect to the basis of settlement reflected in that document, it is further
ORDERED and DECIDED that for 2020, there is no deficiency in petitioner's federal income tax, petitioner's federal income tax has not been overpaid, and petitioner is not liable for an I.R.C. section 6662(a) penalty.