Opinion
13154-21
01-21-2022
DONALD C. MCFADDEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Maurice B. Foley Chief Judge.
On January 5, 2022, the parties filed a Proposed Stipulated Decision resolving the underlying tax liability that is the subject of this proceeding. However, the caption on that document includes a docket number with the letter "S", and this case is not eligible for the small tax case procedures. Consequently, the Court is 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
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Stipulation of Settled Issues. It is further
ORDERED and DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2018 in the amount of $1,720.00; and
That there is no penalty due from petitioner for the taxable year 2018, under the provisions of I.R.C. § 6662(a).