Opinion
24978-22L
07-10-2023
BRIDGETTE LEWIS NAJEV, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy, Special Trial Judge.
On June 30, 2023, the parties filed a Proposed Stipulated Decision. The caption on the Proposed Stipulated Decision contains an incorrect docket number. The Court is therefore 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 hereby
ORDERED that the parties' Proposed Stipulated Decision is recharacterized and treated as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED: That the determinations set forth in the Notice of Determination Concerning Collection Actions Under Internal Revenue Code Sections 6320 and/or 6330 and Your Request for Relief from Joint and Several Liability Under IRC Section 6015 issued to Ms. Najev on September 8, 2022, for her income tax liabilities for the taxable years 2010, 2016, 2017, and 2018, and upon which this case is based, are sustained in full as provided herein;
That the tax imposed on Ms. Najev by the Internal Revenue Code for the taxable years 2010, 2016, 2017, and 2018 are as follows:
Year
Income Tax
I.R.C. § 6651(a)(3) Addition to Tax
I.R.C. § 6654 Addition to Tax
2010
$3,295.09
$1,726.00
$0.00
2016
$6,126.00
$2,820.50
$248.00
2017
$25,070.00
$3,949.11
$318.00
2018
$25,925.00
$6,351.63
$836.00
That Ms. Najev is not entitled to relief under I.R.C. § 6015(b), (c), or (f) for her income tax liabilities for the taxable years 2010, 2016, 2017, and 2018; and
That there are no overpayments in income tax, penalties, or additions to tax due to Ms. Najev for the taxable years 2010, 2016, 2017, and 2018.