Opinion
18094-22S
04-18-2023
MEGAN H. MA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE.
On April 3, 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 both the Proposed Stipulated Decision and the Settlement Stipulation reference an accuracy-related penalty that does not appear to be reflected on the notice of deficiency for 2020 on which this case is based or to have been otherwise pled.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed April 3, 2023, are hereby deemed stricken from the Court's record in this case.