Opinion
14951-23S
05-28-2024
JOSEPH F. SACCO & RACHEL SACCO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On May 23, 2024, the parties filed a Proposed Stipulated Decision. However, the proposed decision document contains a preamble that is improper under the circumstances. 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 is a deficiency in income tax due from petitioners for the taxable year 2021 in the amount of $2,824.00;
That there is no addition to tax under I.R.C. section 6651(a)(1) due from petitioners for the taxable year 2021;
That there is no addition to tax under I.R.C. section 6651(a)(2) due from petitioners for the taxable year 2021; and
That there is no penalty under I.R.C. section 6662(a) due from petitioners for the taxable year 2021.