Opinion
14644-20S
09-01-2021
Johnny L. Grady Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
By notice of deficiency dated September 28, 2020, respondent determined a deficiency of $6, 220.00, an addition to tax under I.R.C. section 6651(a)(1) of $1, 479.50, and an accuracy-related penalty under I.R.C. section 6662(a) of $1, 244.00, for petitioner's 2015 taxable year. Petitioner timely filed a petition for redetermination.
On August 23, 2021, the parties filed a Proposed Stipulated Decision. Therein, the parties agree that petitioner is liable for a deficiency of $3, 666.00 and an addition to tax of $841.00 for the 2015 taxable year. However, the proposed decision does not include any agreement concerning petitioner's liability, if any, for the accuracy-related penalty determined in the notice, and nothing below the signature line of the proposed decision accounts for the foregoing discrepancy in the record.
Accordingly, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed August 23, 2021, is hereby stricken from the record in this case. It is further
ORDERED that, on or before September 24, 2021, the parties shall file a revised Proposed Stipulated Decision that accounts for the I.R.C. section 6662(a) accuracy-related penalty determined in the notice of deficiency upon which this case is based.
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