Opinion
8273-19
10-11-2023
MICHAEL S. PEET & KAREN L. PEET, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On September 28, 2023, the parties filed, among other things, a Proposed Stipulated Decision. However, the proposed decision document improperly refers to the I.R.C. section 6662(a) accuracy-related penalty set forth therein as an "addition[] to tax." Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
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' 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 are deficiencies in income tax and a penalty due from petitioners as follows:
Year
Deficiency
2007
$128,617.00
None
None
2008
$129,384.00
None
$25,876.80