Opinion
637-24S
08-26-2024
KRISTIN PANSERA & PIETRO PANSERA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
The format of the Proposed Stipulated Decision, filed August 23, 2024, does not allow for the document to be processed as styled. That being so, it is
ORDERED that the document is recharacterized and treated 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 for 2021, there is no deficiency in petitioners' federal income tax, and petitioners are not liable for an I.R.C. section 6651(a)(1) addition to tax.