Opinion
25370-21S
11-16-2022
ESTATE OF JANET E. SKINNER, DECEASED, DALE CARLTON, EXECUTOR & DALE CARLTON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy Special Trial Judge
On November 10, 2022, the parties filed a Settlement Stipulation (Doc. 10) and Proposed Stipulated Decision (Doc. 11). Considering the foregoing, the caption on the Settlement Stipulation and Proposed Stipulated Decision contains an error. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
Upon due consideration and to give effect to the agreement of the parties in this case, it is
ORDERED that the parties' Proposed Stipulated Decision, filed November 10, 2022, is recharacterized and treated as the parties' Supplement to Settlement Stipulation. It is further
ORDERED AND DECIDED that, for taxable year 2018, there is a deficiency in income tax due from petitioners in the amount of $5,136.00 and that there is an overpayment in income tax in the amount of $3,160.25, which amount was paid after the issuance of the notice of deficiency;
That there is an addition to tax due from petitioners, under the provisions of I.R.C. § 6651(a)(1), in the amount of $927.00; and
That there is a penalty due from petitioners, under the provisions of I.R.C. § 6662(a), in the amount of $956.00.