Opinion
12318-23
05-17-2024
MOHAMMAD ALI-SHAMAA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 16, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. However, review shows that the decision provides for a deficiency and an addition to tax pursuant to I.R.C. section 6651(a)(1) for the 2017 tax year in that are in excess of those set forth in the underlying notice of deficiency. Such increased amounts do not appear to have been properly pled or otherwise set forth in a specific stipulation agreeing to the increase.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision filed May 16, 2024, is hereby deemed stricken from the Court's record in this case.