Opinion
11389-22
04-29-2024
VICTORIA L. MAITZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Courtney D. Jones, Judge
This case is on the calendar of the Court's April 29, 2024, trial session in St. Louis, Missouri. On April 25, 2024, the parties filed a Proposed Stipulated Decision. Page 2 of the document states "[t]hat there are no overpayments in income tax due to petitioner for the taxable years 2014 and 2015." Upon review of the record, taxable years 2014 and 2015 are not at issue in this case. See Petition (Doc. 1) and Answer (Doc. 8). Upon due consideration, it is
ORDERED that the parties' Proposed Stipulated Decision (Doc. 13) is recharacterized as the parties' Stipulation of Settled Issues. It is further
ORDERED AND DECIDED that there are deficiencies in income tax and additions to tax due from petitioner before the application of I.R.C. § 6015(c) as follows:
| Year | Deficiency | |
| 2009 | $132,753.00 | $33,188.25 |
| 2010 | $145,790.00 | $36,447.50 |
That the following deficiencies in income tax and additions to tax due from petitioner, after the application of I.R.C. § 6015(c):
| Year | Deficiency | |
| 2009 | $0.00 | $0.00 |
| 2010 | $0.00 | $0.00 |