Opinion
12083-23S
01-19-2024
KAKHABERI TETRADZE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Zachary S. Fried Special Trial Judge
On January 18, 2024, the parties filed a Proposed Stipulated Decision for the Court's consideration. A review of that document discloses that it fails to address the penalty under I.R.C. §6662(a) set forth in the notice of deficiency on which this case is based.
Accordingly, upon due consideration, it is
ORDERED that the above-described Proposed Stipulated Decision is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before February 9, 2024, the parties shall file a revised proposed stipulated decision for the Court's consideration.