Opinion
116-23S
01-08-2024
NOAH M. PROUT & ARIEL PROUT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy, Special Trial Judge
On January 4, 2024, the parties filed a Proposed Stipulated Decision. Although executed by counsel for petitioners and counsel for the Commissioner, the Proposed Stipulated Decision fails to reference petitioners in the plural sense. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
For cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed January 4, 2024, is recharacterized and treated as the parties' Settlement Stipulation. To give effect to the basis of settlement reflected in that document, it is further
ORDERED AND DECIDED: That there is a deficiency in income tax due from petitioners for the taxable year 2019 in the amount of $3,333.00; and
That there is no penalty due from petitioners for the taxable year 2019, under the provisions of I.R.C. § 6662(a).