Opinion
37085-21
01-11-2023
JEFFERY M. SEIBERT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge.
This case is scheduled for trial at the session of the Court scheduled to commence on February 6, 2023, in Dallas, Texas.
On January 5, 2023, the parties filed a Proposed Stipulated Decision (Doc. 8). After review, it appears that the Proposed Stipulated Decision makes no mention of the penalty under I.R.C. section 6662(a) that was asserted in the Notice of Deficiency. For this reason, the Proposed Stipulated Decision filed January 5, 2023, is erroneous and will be stricken.
Upon due consideration, it is
ORDERED that the parties' Proposed Stipulated Decision, filed January 5, 2023, is stricken from the Court's record in this case. It is further
ORDERED that this case is stricken from the above-referenced trial session, and the parties are excused from appearing at the calendar call on February 6, 2023. It is further
ORDERED that, on or before April 7, 2023, the parties shall file a proposed stipulated decision. It is further
ORDERED that jurisdiction of this case is retained by the undersigned.