Opinion
5514-20
07-30-2024
MOHAMED K. ABDO & FARDOWSA J. FARAH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On July 29, 2024, the parties filed a Settlement Stipulation and Proposed Stipulated Decision. However, the proposed decision document does not contain sufficient information for the Court to determine the overpayment shown in the document; more specifically, the document does not state the date on which the amount of the overpayment was paid. See I.R.C. § 6512(b)(3). (Based on the Settlement Stipulation, it appears that the amount of the overpayment was deemed paid on April 15, 2019.)
Additionally, the Court notes that the preamble of the Proposed Stipulation Decision is improper under the circumstances and should instead read in relevant part: "Pursuant to the stipulation of the parties in this case, and incorporating herein the facts stipulated by the parties as the findings of the Court".
Upon due consideration of the foregoing, it is
ORDERED that the parties' Proposed Stipulated Decision is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before August 30, 2024, the parties shall file a revised proposed stipulated decision.