Opinion
6463-18SL
01-27-2022
Jarkis T. Fulghem & Shannon P. Fulghem Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Kathleen Kerrigan Judge
On January 24, 2022, the parties filed a proposed stipulated decision which the Court entered on January 26, 2022. Upon further review of the proposed stipulated decision, it appears to have been improperly filed.
Premises considered, it is
ORDERED that the parties' stipulated decision, entered January 26, 2022, is hereby vacated and set aside. It is further
ORDERED that the parties' proposed stipulated decision is recharacterized as the parties' stipulation of settlement. It is further
ORDERED and DECIDED that the determinations set forth in the Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 of the Internal Revenue Code issued to petitioners on February 27, 2018, based upon income tax liabilities for tax years 2012, 2013 and 2014, and upon which this case is based, are sustained in full.