Opinion
2794-22
07-26-2022
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
On July 26, 2022, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, upon review thereof, the Court notes that the proposed decision document includes a typographical error. Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
ORDERED and DECIDED that there is no deficiency in income tax due from, nor overpayment due to, petitioners for the taxable year 2018; and
That there is no penalty due from petitioners for the taxable year 2018 under the provisions of I.R.C. section 6662(a).