Opinion
2604-21
11-10-2022
EUGENE J. DIOU, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On November 4, 2022, the parties filed a Proposed Stipulated Decision. Upon review of the Proposed Stipulated Decision, the Court notes that the parties incorrectly refer to I.R.C. section 6662(a) as an addition to tax. In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
ORDERED and DECIDED that there is no deficiency in income tax due from, nor overpayment due to, petitioner for the taxable year 2018; and
That there is no penalty due from petitioner for the taxable year 2018, under the provisions of I.R.C. section 6662.