The opinion
SAMUEL R. & NANCY A. COLLETTO, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Colletto v. Commissioner
Docket No. 11565-99
United States Tax Court
2000 Tax Ct. Memo LEXIS 130 ;
February 3, 2000 , Decided
*130 EILEEN C. SEAMAN , Counsel for Petitioner. Greenwich, CT.
STUART L. BROWN, Chief Counsel, Internal Revenue Service.
MICHAEL P. BRETON , Attorney.
GERALD A. THORPE , District Counsel, East Hartford, CT.
Thomas B. Wells , Judge
WELLS
DECISION
Pursuant to agreement of the parties in this case, it is
ORDERED AND DECIDED: That there are no deficiencies in income tax due from, nor overpayments due to, the petitioners for the taxable years 1995 and 1996; and
That there are no penalties due from the petitioners for the taxable years 1995 and 1996, under the provisions of I.R.C. § 6662(a) .
* * * *
It is hereby stipulated that the Court may enter the foregoing decision in this case.
It is further stipulated that the petitioners are entitled to litigation and administrative costs under I.R.C. § 7430 in the amount of $ 3,403.00.
Thomas B. Wells
Judge.