Opinion
9962-18
07-08-2022
RAFIK Y. KAMELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
Due to a typographical error in the caption shown on the proposed stipulated decisions, filed June 12 and July 7, 2022, it is
ORDERED that the proposed stipulated decision, filed June 12, 2022, is hereby stricken from the Court's record. It is further
ORDERED that the proposed stipulated decision, filed July 7, 2022 is recharacterized and treated as a stipulation of settlement. To give effect to the basis of settlement agreed upon between the parties as reflected in that document, it is further
ORDERED and DECIDED that there is no deficiency in income tax due from petitioner for the taxable year 2015 and that there is an overpayment in income tax for the taxable year 2015 in the amount of $682.00, which amount petitioner paid on March 3, 2017, and for which amount a claim for refund could have been filed, pursuant to the provisions of I.R.C. §§ 651 l(b)(2) and 6512(b)(3)(B), on February 16, 2018, the date of the mailing of the notice of deficiency;
That there is an addition to tax due from petitioner for the taxable year 2015 under the provisions of I.R.C. § 6651(a)(1) in amount of $187.61.; and
That there is no penalty due from the petitioner for the taxable year 2015 under the provisions of I.R.C. §6662(a).