Opinion
9911-23S
12-08-2023
KEVIN LE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On December 6, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve 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 and Settlement Stipulation fail to address an accuracy-related penalty determined in the notice of deficiency upon which this case is based.
Additionally, the Proposed Stipulated Decision does not appear to comply with Rule 23(a)(4) of the Tax Court Rules of Practice and Procedure.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed December 6, 2023, are hereby deemed stricken from the Court's record in this case.