Opinion
322-22
11-14-2022
ESTATE OF ELAINE C. LUCKEY, DECEASED, PETER A. LUCKEY, ADMINISTRATOR, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
Giving due regard to the representations contained in the proposed stipulated decision, filed July 11, 2022, because the caption is incorrect and the Docket Number was changed when the Court's Order to Show Cause was made absolute, it is
ORDERED that the above-referenced proposed stipulated decision is recharacterized as a stipulation of settlement. In order to give effect to the basis of settlement agreed to by the parties as shown in that document, it is further
ORDERED and DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2015 in the amount of $3,571.00; and
That there is no addition to tax due from petitioner for the 2015 tax year under the provisions of I.R.C. §6651(a)(1), I.R.C. §6651(a)(2), and I.R.C. §6654.