Opinion
1980-21S
12-22-2021
Collins Nnamdi Evulukwu Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Peter J. Panuthos, Special Trial Judge.
For cause, it is
ORDERED that the proposed stipulated decision, filed December 17, 2021, is recharacterized and treated as a stipulation of settlement. To give effect to the agreement between the parties reflected in that document, it is
ORDERED and DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2017 in the amount of $8,505.00, which amount was paid after the mailing of the notice of deficiency, and that there is an overpayment in income tax due to petitioner for the taxable year 2017 in the amount of $3,312.51, which amount was paid after the mailing of the notice of deficiency; and
That there is no penalty due from petitioner for the taxable year 2017 under the provisions of I.R.C. section 6662(a).