Opinion
19490-22S
05-17-2023
SHABNAM NATHIN AHMED CLINTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy, Special Trial Judge
On May 15, 2023, the parties filed a Proposed Stipulated Decision and Settlement Stipulation. The caption on the Proposed Stipulated Decision contains an error. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
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. 13) is recharacterized and treated as the parties' Supplement to Settlement Stipulation. It is further
ORDERED AND DECIDED: That there is a deficiency in income tax due from petitioner for the taxable year 2020 in the amount of $5,471.00, and that there is an overpayment of tax due to petitioner for the taxable year 2020 in the amount of $2,790.57, of which amount $58.57 and $1,387.00 was paid on October l, 2021 and May 16. 2021, respectively, for which amount a claim for refund could have been filed, under the provisions of I.R.C. § 6511(b)(2), on May 31, 2022, the date of the mailing of the notice of deficiency and of which amount $1,345.00 was paid on February 23, 2023, which date is after the mailing of the notice of deficiency; and
That there is no penalty due from petitioner for the taxable year 2020, under the provisions of I.R.C. § 6662(a).