Opinion
6493-20
10-21-2021
Abbas Ali & Huma Abbas Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On October 20, 2021, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolving this litigation. However, review shows that the decision incorporates an addition to tax under the provisions of section 6651(a)(1) of the Internal Revenue Code (I.R.C.) for the taxable year 2015 that exceeds the amount set forth in the underlying notice of deficiency and which has not otherwise been addressed by pleading or accompanying stipulation.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed October 20, 2021, is hereby deemed stricken from the Court's record in this case.