Opinion
4532-20L
04-20-2022
ALAKI M. ELAMA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Judge
For cause, it is
ORDERED that the proposed stipulated decision, filed April 15, 2022, is recharacterized and treated as a stipulation of settlement. In order to give effect to the basis of settlement agreed upon between the parties as reflected in that document, it is further
ORDERED and DECIDED that with respect to petitioner's 2015 outstanding Federal income tax liability, (1) respondent may not proceed with collection as contemplated in the Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330, dated February 7, 2020, a copy of which is attached to the petition, and (2) the collection arrangements contemplated in the supplemental notice of determination, dated February 23, 2022, a copy of which is attached to the joint status report, filed February 25, 2022, are sustained.