Opinion
10686-22
02-08-2023
AYEEZ LALJI & SHELENA C. LALJI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
JOSEPH ROBERT GOEKE, JUDGE
On February 3, 2023, the parties filed a Proposed Stipulated Decision. This is the second proposed stipulated decision that the parties have filed. The first had errors as addressed in the Court's Order served January 31, 2023. The most recent proposed stipulated decision incorrectly uses the singular petitioner when addressing the penalty. While we think this sloppiness is unfortunate, we will enter a decision in accord with the obvious intent of the parties. We will treat the most recent filing by the parties as a stipulation of settled issues. Accordingly, it is
ORDERED that the parties' Proposed Stipulated Decision, filed February 3, 2023, shall be recharacterized as the parties' Stipulation of Settled Issues. It is further
ORDERED and DECIDED that there is a deficiency in income tax due from the petitioners for the taxable year 2019 in the amount of $32,539.00; and
That there is no penalty due from the petitioners for the taxable year 2019 under the provisions of I.R.C. section 6662(a).