Opinion
3058-20
07-22-2022
MY LIEN SHARIATMADARI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
Upon due consideration of the Proposed Stipulated Decision filed October 14, 2021, and the record of this case, it is
ORDERED that the above-referenced document is recharacterized as the parties' Stipulation of Settled Issues. It is further
ORDERED and DECIDED that, pursuant to the parties' stipulation, there is a deficiency in income tax due from petitioner for the taxable year 2016, before the application of §6015(c), in the amount of $44,523.00;
That there is a penalty due from petitioner for the taxable year 2016, under the provisions of §6662(a), before the application of §6015(c), in the amount of $8,904.00;
That there is no deficiency in income tax due from petitioner for the taxable year 2016, after application of §6015(c); and
That there is no penalty due from petitioner for the taxable year 2016 under the provisions of §6662(a), after application of §6015(c).