Opinion
8150-20
02-11-2022
Jennifer A. Sarkisian Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Emin Toro Judge
On February 8, 2022, the parties filed a Proposed Stipulated Decision (Doc. 12) and Settlement Stipulation (Doc. 13). The captions on the Proposed Stipulated Decision and the Settlement Stipulation reflect docket numbers that incorrectly include the letter "S". 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 is recharacterized as the parties' Supplement to Settlement Stipulation. It is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioner for the taxable year 2016 in the amount of $25,794.00, and that there is an overpayment in income tax due to petitioner for the taxable year 2016 in the amount of $7,496.00, which amount was paid on April 15, 2017, and for which amount a claim for refund could have been filed under the provisions of I.R.C. § 6511(b)(2), on February 24, 2020, the date of the mailing of the notice of deficiency; and
That there is no penalty/addition to tax due from petitioner for the taxable year 2016 under the provisions of I.R.C. § 6651(a)(1); and
That there is no penalty/addition to tax due from petitioner for the taxable year 2016 under the provisions of I.R.C. § 6651(a)(2); and
That there is no penalty/addition to tax due from petitioner for the taxable year 2016 under the provisions of I.R.C. § 6654.