Opinion
36058-21S
04-28-2023
JASON A. MALLON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy Special Trial Judge
On April 26, 2023, the parties filed a Proposed Stipulated Decision. The caption on the Proposed Stipulated Decision contains an error. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, and to give effect to the agreement of the parties in this case, it is hereby
ORDERED that the parties' Proposed Stipulated Decision is recharacterized and treated as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there is no deficiency in income tax due from petitioner for the taxable year 2017 and that there is an overpayment for the taxable year 2017 in the amount of $361.60, which amount was paid after the date of the mailing of the notice of the deficiency; and
That there are no additions to tax due from petitioner for the taxable year 2017, under the provisions of I.R.C. §§ 6651(a)(1), 6651(a)(2), and 6654, respectively.