Opinion
3154-21
04-18-2022
RICHARD L. ROONEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Maurice B. Foley, Chief Judge
On April 14, 2022, the parties filed a Proposed Stipulated Decision. However, it is clear to the Court that, based on the record in this case, the proposed decision document includes a typographical error with respect to the taxable year for which there is no penalty due from petitioner (i.e., "207" rather than "2017"). Consequently, the Court is 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
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. It is further
ORDERED and DECIDED that there is no deficiency in income tax due from, nor overpayment due to, petitioner for the taxable year 2017; and
That there is no penalty due from petitioner for the taxable year 2017 under the provisions of I.R.C. section 6662(a).