Opinion
18610-17
10-29-2021
Fabian D. Fonseca & Armandina Fonseca Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Emin Toro, Judge.
On October 26, 2021, the Court received from the parties a Proposed Stipulated Decision (Doc. 34). Upon review, the Court notes that the filing is improper in that it incorporates both consolidated cases in one decision document. In the interest of judicial economy, the Court will not ask the parties to correct and resubmit the decision documents. Rather, upon due consideration, it is hereby
ORDERED that the parties' Proposed Stipulated Decision filed October 26, 2021, shall be recharacterized as the parties' Stipulation of Settled Issues. It is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioners for the taxable years 2014 and 2015 in the amount of $41, 537.00 and $70, 248.00, respectively; and
That there are penalties due from petitioners for the taxable years 2014 and 2015, under the provisions of Internal Revenue Code section 6662(a), in the amounts of $8, 307.40 and 14, 049.60, respectively. 1