Opinion
12350-23S
09-11-2023
TIMOTHY A. DUMMER & SANDRA A. TRAYNOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 7, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purportedly resolving this litigation. That decision was premised on a Settlement Stipulation filed the same date establishing an overpayment for the underlying 2020 taxable year. However, review shows that the Proposed Stipulated Decision bears an incorrect Docket No. on the Settlement Stipulation fails to attach the Statement of Account referenced therein reflecting such overpayment.
Additionally, prior to entry of any stipulated decision, however, it is advisable to ensure that the record herein is complete insofar as concerns the documentation (1) relevant to establish the Court's jurisdiction over all parties and taxable periods and/or (2) referenced in the decision.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed September 7, 2023, are hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before September 29, 2023, respondent shall file a report and shall attach thereto a copy of the notice of deficiency for 2020 issued to petitioners.