Opinion
8898-22
11-28-2023
DANIEL IBRAGIMOV & YULIA IBRAGIMOV, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge.
On November 21, 2023, the parties filed a Proposed Stipulated Decision. Upon further review of the record, the Court determined that petitioner Daniel Ibragimov's name had been incorrectly entered in the caption of this case. The caption was amended by order issued November 28, 2023.
Because of the error contained in the parties' proposed decision document, the Court is unable to enter it. Nevertheless, the agreement of the parties in this case is clear to the Court.
Upon due consideration, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed November 21, 2023, is recharacterized as the parties' 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 a deficiency in income tax due from petitioners for taxable year 2019 in the amount of $52,205,00; and
That there is a penalty under I.R.C. section 6662(a) due from petitioners for taxable year 2019 in the amount of $7,289.77.