Opinion
34720-21
08-09-2023
CANDACE R. TAYLOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On August 8, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. That decision was premised on a Settlement Stipulation filed the same date purportedly establishing an overpayment for the underlying 2016 taxable year. However, the submissions raise two concerns. First, the Proposed Stipulated Decision incorrectly refers to an accuracy-related penalty under section 6662(a) of the Internal Revenue Code (I.R.C.) as an addition to tax. Second, the Settlement Stipulation indicates that the attached Statement of Account reflects petitioner's income tax liability after application of section 6015(f), I.R.C. Yet the Statement of Account shows balances due, rather than an overpayment, seemingly demonstrating the situation before application of section 6015(f), I.R.C.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed August 8, 2023, are hereby deemed stricken from the Court's record in this case.