Opinion
24281-22L
09-06-2023
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On September 1, 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration. Because the parties have attached a document to the proposed decision document, the Court is unable to enter it.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
ORDERED AND DECIDED that the determinations set forth in the Notice of Determination Concerning Collection Actions under Sections 6320 or 6330 of the Internal Revenue Code, issued to petitioner on October 19, 2022, with respect to petitioner's income tax liabilities for the taxable year 2016, and upon which this case is based, as supplemented by the Supplemental Notice of Determination, issued to petitioner on August 4, 2023, are sustained in full.