Opinion
11925-22
05-23-2023
ERIC LEE MCCULLOUGH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge.
For cause, it is
ORDERED that the parties' proposed stipulated decision, filed May 17, 2023, is recharacterized as a stipulation of settlement. In order to give effect to the basis of settlement reflected in that document, it is further
ORDERED AND DECIDED: That there is a deficiency in income tax due from the petitioner in the amount of $258.00 for the taxable year 2018;
That there is an addition to tax due from petitioner in the amount of $210.00 for the taxable year 2018 under the provisions of I.R.C. § 6651(a)(1);
That there is an addition to tax due from petitioner for the taxable year 2018, under the provisions of I.R.C. § 6651(a)(2), of 0.5% of the unpaid income tax shown on the return, commencing on the due date of petitioner's return and accruing for each month or fraction thereof during which petitioner fails to pay, not exceeding 25% in the aggregate; and
That there is no addition to tax due from the petitioner for taxable year 2018 under the provisions of I.R.C. § 6654.