Opinion
11539-22
06-27-2023
ELIZABETH A. FITZPATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Patrick J. Urda Judge
This case was called from the calendar during the Court's San Diego, California trial session on June 20, 2023. There was no appearance by or on behalf of petitioner Elizabeth A. Fitzpatrick. Counsel for the Commissioner appeared and informed the Court that the parties have reached a basis for settlement and that a proposed stipulated decision document will be filed soon.
On June 20, 2023, the parties filed a proposed stipulated decision. Upon review, it appears that the proposed stipulated decision contains a typographical error. In lieu of having the parties re-submit another proposed stipulated decision, the Court will enter its own decision that embodies the substance of the parties' agreement. Upon due consideration, it is
ORDERED that the parties' proposed stipulated decision shall be recharacterized as a stipulation of settled issues. It is further
ORDERED and DECIDED that there are deficiencies in income tax and additions to tax due from petitioner as follows:
Addition to Tax Under I.R.C. §§
Year
Deficiency
6651(a)(1)
6651(a)(2)
2016
$102,219
$0
$1,201.752017
$45,260
$0
$4,841.00