Opinion
13342-23L
07-19-2024
PETER A. ROMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Emin Toro Judge
On July 11, 2024, the parties filed a Proposed Stipulated Decision (Doc. 19). However, upon review of the Proposed Stipulated Decision, the Court notes that there is a typographical error contained in the Proposed Stipulated Decision. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, and to give effect to the agreement of the parties in this case, it is hereby
ORDERED that the parties' Proposed Stipulated Decision (Doc. 19) filed July 11, 2024, is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that the determinations set forth in the Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330 issued to petitioner on July 25, 2023, for petitioner's income tax liability for taxable periods 2012 and 2016, and upon which this case is based are not sustained, and that the determinations as supplemented by the Supplemental Notice of Determination Concerning Collection Actions under Internal Revenue Code Section 6320 or 6330 issued to petitioner on April 26, 2024, are sustained.