Opinion
18563-23S
08-08-2024
JESSICA BRIDE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 7, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. That decision was premised on a Settlement Stipulation filed the same date establishing an overpayment for the underlying 2021 taxable year. However, review shows that the Proposed Stipulated Decision and the Settlement Stipulation appear to be inconsistent. Specifically, the Proposed Stipulated Decision states that the amount of the overpayment "was paid on after the mailing of the notice of deficiency". Conversely, the notice of deficiency is dated August 28, 2023, but the Settlement Stipulation reflects no payments made after that date. The payment date indicated by the Settlement Stipulation seems to be August 3, 2023.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed August 7, 2024, are hereby deemed stricken from the Court's record in this case.