Opinion
1733-23
04-28-2023
SARA A. MARSHALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 28, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving 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 both address an accuracy-related penalty that does not appear to have been determined in the notice of deficiency on which this case is based or otherwise pled by the parties.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed April 28, 2023, are hereby deemed stricken from the Court's record in this case.