Opinion
32104-21S
03-29-2022
DOUGLAS RECHSTEINER & LISA RECHSTEINER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge.
On March 25, 2022, the parties filed a Proposed Stipulated Decision. However, the Court notes that, although the preamble of the proposed decision document references "the stipulation of the parties filed in this case", no such stipulation is reflected in the record. Additionally, the Court notes that, although the proposed decision document references an I.R.C. section 6662(a) penalty, no such penalty appears to be at issue in this case. The Notice of Deficiency upon which this case is based did not determine that petitioners were liable for an I.R.C. section 6662(a) penalty, and respondent did not affirmatively assert such a penalty in the Answer.
In view of the foregoing, the Court is unable to process the parties' Proposed Stipulated Decision.
Accordingly, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed March 25, 2022, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before April 28, 2022, the parties shall file a revised proposed stipulated decision.