Opinion
10077-21
01-04-2023
CHRISTOPHER F.D. RYDER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This case was scheduled for trial at the remote session of the Court scheduled to commence on December 12, 2022, for Baltimore, Maryland. Respondent filed a status report on November 21, 2022, advising the Court that a basis for settlement had been reached and requesting additional time to file a proposed stipulated decision with the Court. By order dated November 30, 2022, this case was stricken from the aforementioned trial session and jurisdiction retained by the undersigned.
On December 22, 2022, the parties filed with the Court a Proposed Stipulated Decision (Doc. 11). That proposed decision reflects an addition to tax under the provisions of section 6651(a)(2) for taxable year 2017 that differs from the amount reflected in the notice of deficiency dated December 14, 2020, upon which this case is based. The section 6651(a)(2) addition to tax reflected in the notice of deficiency is in the amount of $6,227 whereas the section 6651(a)(2) addition to tax reflected in the stipulated decision filed December 22, 2022, is in the amount of $8,438. There is no accompanying stipulation to provide for such increase.
All statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times. All monetary amounts are rounded to the nearest dollar.
It is therefore, ORDERED that, the parties' joint Proposed Stipulated Decision filed December 22, 2022 (Doc. 11), is hereby stricken from the record and shall not be made viewable as part of this case. It is further
ORDERED that, on or before February 3, 2023, the parties shall file a proposed stipulated decision, stipulation of settled issues (or both), or status report (jointly if possible, otherwise independently) that provides the Court with the then-present status of the case.