Opinion
8281-22
08-30-2024
NAYNIB, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Ronald L. Buch, Judge
On August 28, 2024, the parties submitted to the Court a proposed stipulated decision. The last paragraph of that decision listed three years for which an addition to tax under section 6651(a)(2) applies but listed four amounts. Notwithstanding the discrepancy, the parties' intent is clear. Accordingly, it is
ORDERED that the Clerk shall recharacterize the parties' Proposed Stipulated Decision as a Stipulation of Settlement. It is further
ORDERED and DECIDED:
That there are deficiencies in I.R.C. § 4941(a)(1) first tier excise tax due from the petitioner for the taxable years 2016, 2017, 2018, and 2019 in the amounts of $521.00, $1,043.00, $1,607.00, and $1,110.00 respectively;
That there is no deficiency in I.R.C. § 4941(b)(1) second tier excise tax due from the petitioner for the taxable year 2019.
That there are additions to tax due from the petitioner for the taxable years 2016, 2017, 2018, and 2019 under the provisions of I.R.C. § 6651(a)(1) in amounts of $117.00, $235.00, $362.00, and $250.00, respectively; and
That there are additions to tax due from the petitioner for the taxable years 2016, 2017, 2018, and 2019 under the provisions of I.R.C. § 6651(a)(2) in amounts of $130.00, $261.00, $370.00, and $189.00, respectively.