Opinion
17809-22L
11-01-2022
DAVIDE GOLIA & THERESA F. GOLIA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
For cause, it is
ORDERED that the parties' proposed stipulated decision, filed October 28, 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 the determinations set forth in the Notice of Determination Concerning Collection Actions Under Section 6320 or 6330 of the Internal Revenue Code issued to petitioners on July 26, 2022, for petitioners' income tax liability for the taxable year 2013, and upon which this case is based, are sustained in full.