Opinion
11833-20
03-04-2022
ESTATE OF ALFRED SOMBOUN YIN, DECEASED, WOOIYI TAN YIN, EXECUTOR, AND WOOIYI T. YIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge.
On February 28, 2022, the parties filed a proposed stipulated decision, which states that the deficiency in income tax due from petitioners for the taxable year 2017 is $60, 525.00 (docket entry no. 13). The Notice of Deficiency, dated June 23, 2020, and attached to the petition shows a deficiency of $60, 249.00 for 2017 (docket entry no. 1). The increase to the deficiency is neither pled to nor stipulated to on the record. Accordingly, it is
ORDERED that on or before April 1, 2022, the parties shall file a response to this Order (jointly if possible, otherwise separately) explaining their position(s) on the aforementioned discrepancy. 1