Opinion
7114-24
07-03-2024
Y. A. PASTREICH & PENNY OSTREICHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge.
On July 1, 2024, the parties filed a Proposed Stipulated Decision. Because of a typographical error contained in the proposed decision document, the Court is unable to enter it. Nevertheless, the agreement of the parties, as reflected in that document, is clear to the Court.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' above-referenced 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, petitioners for the taxable year 2021; and
That there is no penalty due from petitioners for the taxable year 2021 under the provisions of I.R.C. section 6662(a).