Opinion
25864-22
08-21-2023
FABIAN HERNANDEZ LIMON & JUVENTINA QUINONES RIVAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 16, 2023, the parties filed, inter alia, a Proposed Stipulated Decision. However, that filing is improper in that the proposed decision document does not address petitioners' liability, if any, for the I.R.C. section 6651(a)(1) addition to tax determined in the Notice of Deficiency upon which this case is based. That being so, it is
ORDERED that the parties' Proposed Stipulated Decision is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before September 20, 2023, the parties shall file (1) a revised proposed stipulated decision or (2) a joint report regarding the then-present status of this case.