Opinion
17714-22
08-22-2022
NAJIBULLAH NAJIB AKRAMI & GULSUM NAJIB AKRAMI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 8, 2022, the Court filed a Letter by Petitioner. Therein, petitioner Najibullah Najib Akrami advises that petitioners have reached an agreement with the Internal Revenue Service in this case and have received an IRS Notice CP3581 "No Change Letter" dated August 1, 2022. A copy of the so-called "No Change Letter", indicating that the examination of petitioners' 2019 taxable year has been closed with no changes, is attached to petitioner's Letter.
In a deficiency case where this Court has jurisdiction, the Court is generally required to enter a decision specifying the amount of the deficiency, if any, for the taxable year at issue. See I.R.C. § 7459(d); Estate of Ming v. Commissioner, 62 T.C. 519 (1974). Therefore, even if the parties have reached a settlement, as it appears may have occurred in this case, the Court must enter a decision. Accordingly, we will recharacterize the Letter and direct the parties as set forth below.
Upon due consideration of the foregoing, it is
ORDERED that the above-referenced Letter is recharacterized as petitioners' Motion for Entry of Decision. It is further
ORDERED that, on or before October 21, 2022, respondent shall file a response to the Motion for Entry of Decision, or the parties shall file a proposed stipulated decision.