Garcia v. Comm'r of Internal Revenue

Full title: SAMUEL GARCIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jun 14, 2022

No. 10405-21S (U.S.T.C. Jun. 14, 2022)

Opinion

10405-21S

06-14-2022

SAMUEL GARCIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Adam B. Landy Special Trial Judge

ORDER

Adam B. Landy Special Trial Judge

This case is calendared for trial at the session of the Court scheduled to commence at Los Angeles, California on September 19, 2022.

On June 10, 2022, the parties filed a Proposed Stipulated Decision (Doc. 10). The Proposed Stipulated Decision does not address the failure to file addition to tax, pursuant to I.R.C. § 6651(a)(1), raised in the notice of deficiency, dated January 4, 2021. The Proposed Stipulated Decision does address a failure to pay addition to tax, pursuant to I.R.C. § 6651(a)(2), not raised in the notice of deficiency. The Court is therefore unable to process the parties' Proposed Stipulated Decision.

Upon due consideration, it is

ORDERED that the parties' Proposed Stipulated Decision, filed June 10, 2022, is hereby deemed stricken from the Court's record and shall not be viewable as part of this case. It is further

ORDERED that, on or before July 14, 2022, the parties shall submit a revised Proposed Stipulated Decision or Status Report (preferably a joint report) to inform the Court of the then-present status of the case.