Opinion
13368-22
11-08-2022
JOSE A. CALZADA RIOS & ITZEL GISELA ADAN SANCHEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of the Proposed Stipulated Decision, filed November 1, 2022, and petitioners' Motion for Leave to File Motion for Reasonable Litigation or Administrative Costs, filed November 4, 2022, it is
ORDERED that the Proposed Stipulated Decision is hereby recharacterized as the parties' stipulation of settled issues. It is further
ORDERED that petitioners' motion for leave is denied, without prejudice, on the ground that no Motion for Reasonable Litigation or Administrative Costs was lodged with the above-referenced motion for leave.