Opinion
19051-22S
08-28-2023
TYLER A. DIRKS & KARA A. DIRKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On August 22, 2023, the parties filed a Settlement Stipulation and Proposed Stipulated Decision for the Court's consideration. Because of a typographical error contained in the proposed decision document, the Court is unable to enter it. Nevertheless, the agreement of the parties, as reflected in that document, is clear to the Court.
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' Stipulation of Settlement. Taking into account the basis for settlement reached between the parties, as reflected in that document, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioners for the taxable year 2020 in the amount of $1,050.00, and that there is an overpayment in income tax due to petitioners for the taxable year 2020 in the amount of $1.00, which amount was paid on March 21, 2022, and for which amount a claim for refund could have been filed, under the provisions of I.R.C. section 6511(b)(2), on August 8, 2022, the date of the mailing of the notice of deficiency; and
That there is no penalty under I.R.C. section 6662(a) due from petitioners for the taxable year 2020.