Opinion
36494-21
01-04-2023
ROBERT THOMAS JOHNSON & HALEY RENEE JOHNSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
On January 3, 2023, the parties filed a Proposed Stipulated Decision (Doc. 7). The Proposed Stipulated Decision failed to address the civil fraud penalty reflected in the notice of deficiency upon which the case is based, although it reflected a penalty under section 6662(a), which was not reflected in the notice of deficiency. Upon due consideration, it is hereby
ORDERED that the parties' Proposed Stipulated Decision filed January 3, 2023, is stricken from the record in this case.