Opinion
6015-21
02-11-2022
Lawrence A. Smith & Ana M. Smith Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Maurice B. Foley, Chief Judge
For cause, it is
ORDERED that the parties' proposed stipulated decision, filed January 21, 2022, is recharacterized as a stipulation of settlement. In order to give effect to the basis of settlement reflected in that document, it is further
ORDERED and DECIDED that, with respect to petitioners' 2018 tax year, there is no deficiency in income tax due from and no overpayment due to petitioners, and that petitioners are not liable for an I.R.C. section 6662 penalty. 1