Opinion
18254-23
01-18-2024
MICHAEL DIGGS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On January 11, 2024, the parties filed a Proposed Stipulated Decision. Because the Proposed Stipulated Decision includes an erroneous reference to petitioner in the plural sense, the Court is unable to enter it. Nevertheless, the agreement of the parties in this case is clear to the Court.
In view of the foregoing, to give effect to the agreement of the parties, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed January 11, 2024, is recharacterized as the parties' Settlement Stipulation. To give effect to the basis of settlement reflected in that document, it is further
ORDERED AND DECIDED: That there is a deficiency in income tax due from petitioner for the taxable year 2021 in the amount of $7,009.00; and
That there is no penalty due from petitioner for the taxable year 2021, under the provisions of I.R.C. § 6662(a).