Opinion
25215-21S
10-07-2022
ROBERT STEPHEN GARRINGER & BARBARA LYNN GARRINGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
As the parties' proposed stipulated decision, filed September 23, 2022, bears an incorrect caption for this case, it is
ORDERED that the parties' proposed stipulated decision, filed September 23, 2022, is recharacterized as a stipulation of settlement. In order to give effect to the basis of settlement reflected in that document, it is further
ORDERED and DECIDED that there is no deficiency in income tax due from, and no overpayment due to, petitioners for the taxable year 2019; and
That there is no penalty due from petitioners for the taxable year 2019 under the provisions of I.R.C. section 6662(a).