Opinion
12021-22S
03-06-2023
JOSEPH AARON HERRERA & NICOLE EMICK HERRERA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo, Chief Special Trial Judge
The proposed stipulated decision, filed March 2, 2023, makes a reference to 2017, a year not in dispute in this case for the redetermination of a deficiency. The record demonstrates that the deficiency placed in dispute in this proceeding relates to 2019. That being so, it is
ORDERED that the above-referenced proposed stipulated decision is recharacterized and treated as a stipulation of settlement. To give effect to the basis of settlement reflected in that document, it is further
ORDERED and DECIDED that for 2019, there is a is a $12,666 deficiency in petitioners' federal income tax, and that petitioners are liable for a $2,532 I.R.C. section 6662(a) penalty.