Opinion
17171-23S
09-13-2024
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
The Stipulation filed September 12, 2024, shows among other things, that the parties have settled petitioner's liability for an I.R.C. section 6662(a) penalty, but the Proposed Stipulated Decision, also filed September 12, 2024, makes no reference to that penalty. Premises considered, it is
ORDERED that the above-referenced Proposed Stipulated Decision is recharacterized and treated as a stipulation of settled issues.