Opinion
18347-22
01-18-2024
MAXINE WORKMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
David Gustafson Judge.
This is a "collection due process" case brought under I.R.C. section 6330, but the character of the case was not evident at the time the original petition was filed and the docket number was assigned. The parties have now settled the case and have filed a proposed stipulated decision. The Court appreciates the work that was done to accomplish this. So that the record of this case will accurately reflect its character, it is
ORDERED that the Clerk of the Court shall add the suffix "L" to the docket number of this case. That suffix is missing from the caption as it appears on the parties' proposed stipulated decision, so it is further
ORDERED that the Clerk of the Court shall recharacterize the proposed stipulated decision as a stipulation of settled issues. It is further
ORDERED and DECIDED: That the determination set forth in the Notice of Determination Concerning Collection Action under Section 6320 and/or 6330 issued to petitioner on July 26, 2022, for petitioner's income tax liabilities for the 2016, 2017, and 2019 taxable years, is sustained in full.