Opinion
3357-23
04-28-2023
SANTOS M. CANALES & GRISELDA U. CANALES,Petitioners v. COMMISSIONER OF INTERNAL REVENUE,Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On April 27, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving 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 incorrectly refers to the penalty under section 6676 of the Internal Revenue Code (I.R.C.) as an addition to tax.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed April 27, 2023, are hereby deemed stricken from the Court's record in this case.