Opinion
12455-23
11-04-2024
THERESA FRANCIA NUTTER Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge.
For cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed November 1, 2024, is recharacterized as a Stipulation of Settlement. In order to give effect to the basis of settlement reflected in that document, it is further
ORDERED and DECIDED that there are deficiencies in income tax due from petitioner for the taxable years 2019, 2020, and 2021 in the amounts of $23,986.00, $31,026.00, and $13,027.00, respectively;
That there is no addition to tax due from petitioner for the taxable year 2020 under the provisions of I.R.C. § 6651(a)(l); and
That there are penalties due from petitioner for the taxable years 2019, 2020, and 2021 under the provisions of I.R.C. § 6662(a) in the amounts of $4,797.20, $6,205.20, and $2,605.40, respectively.