Opinion
36772-21
04-12-2022
DONALD SCOTT TIMM & ALICIA PONCY TIMM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo, Chief Special Trial Judge
Because the proposed stipulated decision, filed April 8, 2022, makes reference to an I.R.C. section 6662(a) penalty that has not otherwise been placed in dispute in this proceeding for the redetermination of a deficiency, it is
ORDERED that the above-referenced proposed stipulated decision is recharacterized and treated as a stipulation of settlement. To give effect to the basis of settlement agreed upon between the parties as reflected in that document, it is further
ORDERED and DECIDED that there is a $2, 319 deficiency in petitioners' 2018 Federal income tax.