Opinion
18956-22S
07-03-2024
MARK EMERY ARCHER & ELISABETH A. TEMPLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge
On June 27, 2024, the parties filed a Proposed Stipulated Decision. However, because of certain discrepancies, the Court is unable to enter the proposed decision document as currently drafted.
Specifically, the notice of deficiency on which this case is partly based imposes a penalty under I.R.C. section 6662(a) for tax year 2018 on both petitioners. However, the Proposed Stipulated Decision does not address petitioner Elisabeth A. Templer's liability for this 2018 penalty.
In addition, the Proposed Stipulated Decision states, "That there is no overpayment in income tax or penalties due to petitioners for the taxable years 2018 or 2019." However, no notice of deficiency was issued to petitioner Elisabeth A. Templer for tax year 2019, and her liability for income tax and penalties for that year is not before the Court.
Finally, as drafted, the Proposed Stipulated Decision includes two pages that are paginated as "-2-".
Upon due consideration of the foregoing, it is
ORDERED that the parties' Proposed Stipulated Decision, filed June 27, 2024, is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before August 2, 2024, the parties shall file a corrected proposed stipulated decision.