Opinion
22455-19
04-22-2022
ESTATE OF OM P. RATTAN, DECEASED, v. COMMISSIONER OF INTERNAL REVENUE, Respondent DONOR, MANU RATTAN, PERSONAL REPRESENTATIVE, Petitioners
ORDER AND DECISION
Maurice B. Foley, Chief Judge.
For cause, it is
ORDERED that the parties' proposed stipulated decision, filed April 20, 2022, is recharacterized as a stipulation of settlement. In order to give effect to the basis of settlement reflected in that document, it is further
ORDERED AND DECIDED: That there are deficiencies in gift tax due from petitioners for the calendar years 2006, 2007, 2008, 2009, and 2010 in the amounts of $334, 638.00, $24, 754.00, $126, 658.00, $95, 108.00, and $54, 000.00, respectively;
That there is no penalty due from petitioners for the taxable year 2006, under the provisions of l.R.C. § 6662(a) or 6662(h);
That there are additions to tax due from petitioners for the taxable years 2007, 2008, 2009, and 2010, under the provisions of I.R.C. § 665 l(a)(1), in the amounts of $5, 570.00, $28, 498.00, $21, 399.00, and $12, 150.00, respectively; and
That there are additions to tax due from petitioners for the taxable years 2007, 2008, 2009, and 2010, under the provisions of I.R.C. § 6651(a)(2), in the amounts of $6, 189.00, $31, 665.00, $23, 777.00, and $13, 500.00, respectively.