Opinion
26942-22S
06-14-2023
GUILLERMO PRECIADO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge.
This case is calendared for trial at the October 23, 2023, Fresno, California, Trial Session of the Court.
On June 13, 2023, the parties filed a Proposed Stipulated Decision. Upon review, it appears that the decision references an accuracy-related penalty under I.R.C. § 6662(a), that is not reflected in the notice of deficiency dated September 6, 2022. Accordingly, the Court will strike the proposed stipulated decision. Upon due consideration and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision filed June 13, 2023,is hereby stricken from the Court's record.