Opinion
3503-23S
12-05-2023
RICHARD L. DETRICK & JEANETTE A. DETRICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
Because the Proposed Stipulated Decision, filed December 4, 2023, (1) references a document not included in the record, and (2) references the wrong year in the portion of the document addressing petitioners' liability for an I.R.C. section 6662(a) penalty, 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 a $4,874 deficiency in petitioners' federal income tax, and petitioners are not liable for an I.R.C. section 6662(a) penalty.