Opinion
17784-12
07-31-2024
STANLEY BATTAT & ZMIRA BATTAT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge.
On July 29, 2024, petitioners filed a Motion for Entry of Decision. In that Motion, petitioners state that they agree to the Court entering a decision in specific amounts but that they do not waive their right to appeal. The Court granted their Motion for the reasons stated. They now ask the Court to amend its Order and Decision to include a paragraph regarding the petitioner's stipulation as to what they do and do not concede.
The Court does not include in its orders or decision what petitioners do or do not stipulate. They could have filed a proposed stipulated decision with a "below the line" stipulation (i.e., a stipulation below the Judge's signature but above theirs). They did not. They filed a Motion in which they made plain their stipulation. The Court granted that Motion for the reasons stated, which includes acknowledgement of petitioners' stipulation. Nothing further needs to be done. Accordingly, it is
ORDERED that petitioners' Motion to amend Order filed July 30, 2024, is denied.