Opinion
11486-22S
03-24-2023
MARCELLA ELIZABETH WOLFE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy, Special Trial Judge
On March 22, 2023, the parties filed a Proposed Stipulated Decision. The caption on the Proposed Stipulated Decision contains an error. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, and to give effect to the agreement of the parties in this case, it is hereby
ORDERED that the parties' Proposed Stipulated Decision is recharacterized and treated as the parties' Settlement Stipulation. It is further
ORDERED AND DECIDED that there is no deficiency in income tax due from, nor overpayment due to, the petitioner for taxable year 2019; and
That there is no penalty due from the petitioner for the taxable year 2019 under the provisions of I.R.C. § 6662(a).