Opinion
30156-21
12-05-2023
ADAM D. PERKINS & SHELBY J. PERKINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
On November 29, 2023, the parties filed a proposed stipulated decision in this case. The proposed decision, however, is silent as to the I.R.C. section 6651(a)(1) addition to tax for taxable year 2014 asserted in the Notice of Deficiency at issue in this case. The proposed decision also asks the Court to enter an I.R.C. section 6662(a) penalty for taxable year 2014 in excess of the amount asserted in the Notice of Deficiency. The amount of the I.R.C section 6662(a) penalty appears to be a combination of the asserted 6651(a)(1) addition to tax and 6662(a) penalty asserted in the Notice of Deficiency, however, the record in this case lacks any explanation as to the increase. Premises considered, it is
ORDERED that the parties proposed stipulated decision, filed November 29, 2023, is hereby stricken from the record in this case. It is further
ORDERED that the parties shall, on or before December 30, 2023, file with the Court a corrected proposed stipulated decision.