Opinion
23083-21
06-16-2022
JAMES RIDINGER & LOREN M. RIDINGER Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 15, 2022, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. However, review shows that the decision fails to address a penalty under section 6663 and an addition to tax under section 6662(h) of the Internal Revenue Code (I.R.C.) for 2016 reflected on the faces of the underlying notices of deficiency issued to James Ridinger and Loren M. Ridinger, respectively. The Court would also have expected the stipulations below the judicial signature to clarify the amounts under section 6662, I.R.C., resulting from the acceptance of one of the alternative positions as to both taxpayers.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed June 15, 2022, is hereby deemed stricken from the Court's record in this case.