Milner v. Comm'r of Internal Revenue

Full title: ROBERT MILNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Aug 21, 2023

No. 10084-23 (U.S.T.C. Aug. 21, 2023)

Opinion

10084-23

08-21-2023

ROBERT MILNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge.

ORDER AND DECISION

Kathleen Kerrigan Chief Judge.

On August 18, 2023, the parties filed a Proposed Stipulated Decision. However, the proposed decision document improperly refers to the additions to tax determined in the Notice of Deficiency as "penalties." Consequently, the Court is unable to process the Proposed Stipulated Decision.

In view of the foregoing, to give effect to the agreement of the parties, 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, petitioner for the taxable year 2018;

That there is no addition to tax under I.R.C. section 6651(a)(1) due from petitioner for the taxable year 2018;

That there is no addition to tax under I.R.C. section 6651(a)(2) due from petitioner for the taxable year 2018; and

That there is no addition to tax under I.R.C. section 6654 due from petitioner for the taxable year 2018.