Opinion
7165-23
04-09-2024
DAVID JACOBSON Petitioner, 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 March 18, 2024, is recharacterized as a Stipulation of Settlement. Pursuant to that stipulation of the parties and to the parties' Settlement Stipulation, also filed March 18, 2024, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is further
ORDERED AND DECIDED: That there is a deficiency in income tax due from petitioner for taxable year 2019 in the amount of $8,823.00; that there is an overpayment in income tax for the taxable year 2019 in the amount of $17,297.00, which amount was paid on April 15, 2020, and for which amount a claim for refund could have been filed, under the provisions of I.R.C. section 6511(b)(2), on February 6, 2023, the date of the mailing of the notice of deficiency;
That there is no addition to tax under I.R.C. section 665l(a)(1) due from petitioner for taxable year 2019;
That there is no addition to tax under I.R.C. section 6651(a)(2) due from petitioner for taxable year 2019; and
That there is no addition to tax under I.R.C. section 6654 due from petitioner for taxable year 2019.