Opinion
794-22
02-23-2023
CHAD ANTHONY DELAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Emin Toro, Judge
On February 14, 2023, the parties filed a Proposed Stipulated Decision (Doc. 10). However, upon review of the Proposed Stipulated Decision, the Court notes that the name of petitioner in the caption does not match the caption of this case. 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. 10) filed February 14, 2023, is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there are no income taxes due from petitioner for the taxable years 2015, 2016, 2017, and 2018, after application of I.R.C. § 6015(f);
That there are no additions to tax due from petitioner for the taxable years 2015, 2016, 2017, and 2018 under the provisions of I.R.C. § 6651(a), after application of I.R.C. § 6015(f); and
That there are no overpayments in income tax or additions to tax due to petitioner for the taxable years 2015, 2016, 2017, and 2018.