Opinion
13091-21S
03-23-2022
EMMANUEL J. FAURE & KRISTEN FAURE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy Special Trial Judge.
On March 21, 2022, the parties filed a Proposed Stipulated Decision. The Proposed Stipulated Decision fails to reference petitioners in the plural sense in the caption and body of the decision. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing and to give effect to the agreement of the parties in this case, it is hereby
ORDERED that the parties' Proposed Stipulated Decision, filed March 21, 2022, is recharacterized and treated as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there is no deficiency in income tax due from petitioners for the taxable year 2018; and
That there is no penalty due from petitioners for the taxable year 2018, under the provisions of I.R.C. § 6662(a).