Opinion
795-21
02-18-2022
ORDER AND DECISION
Maurice B. Foley Chief Judge
Upon review of the parties' proposed stipulated decision, filed January 26, 2022, it is
ORDERED that the proposed stipulated decision is recharacterized as a stipulation of settlement. In order to give effect to the basis of settlement reflected in that stipulation of settlement, it is
ORDERED and DECIDED that there is no deficiency in income tax due from petitioner, nor overpayment due to petitioner, for the taxable year 2016. It is further
ORDERED and DECIDED that there is no addition to tax due from petitioner for the taxable year 2016 under the provisions of I.R.C. § 665l(a)(1). It is further
ORDERED and DECIDED that there is no addition to tax due from petitioner for the taxable year 2016 under the provisions of I.R.C. § 6651(a)(2). It is further
ORDERED and DECIDED that there is no addition to tax due from petitioner for the taxable year 2016 under the provisions of I.R.C. § 6654.