Opinion
4872-17
04-11-2023
BONNIE G. DONOHUE REVOCABLE TRUST DATED 8/24/2006, BONNIE G. DONOHUE, TRUSTEE, TRANSFEREE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Emin Toro, Judge
On April 7, 2023, the parties filed a Proposed Stipulated Decision (Doc. 49). 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. 49) filed April 7, 2023, is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there is a total liability in the amount of $666,782.30, plus interest as provided by law from November 28, 2016, to the date such liability is paid, due from petitioner as transferee of assets of JSB Montana, Inc., f.k.a. Continental Television Network, Inc., transferor, for unpaid income tax of the transferor for the taxable year ended November 30, 2001.