Opinion
34045-21
03-10-2022
Randy R. Wilder & Katrina E. Wilder 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 27, 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 there is no deficiency in income tax for petitioners for the taxable year 2019, and that there is an overpayment in income tax due to petitioners for the taxable year 2019 in the amount of $1,957.00, which was paid on July 14, 2020, and for which amount a claim for refund could have been filed under the provisions of I.R.C. § 6511(b)(2) on September 27, 2021 the date of the mailing of the notice of deficiency; and
That there is no penalty due from petitioners for the taxable year 2019 under the provisions of I.R.C. § 6662(a).