Opinion
16484-22S
09-22-2022
MICHAEL VINCENT JERMAINE CARTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
On September 13, 2022, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, the Court notes that the preamble of the proposed decision document is improper under the circumstances. Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
Upon due consideration and further review of the record; in order to give effect to the agreement of the parties in this case; and for cause, it is
ORDERED that the Petition, filed July 27, 2022, is hereby deemed to have been ratified and affirmed by petitioner. It is further
ORDERED that, on the Court's own motion, so much of this case relating to a Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the Department of State for the taxable year 2019 is dismissed for lack of jurisdiction and deemed stricken from the Court's record in this case. It is further
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
ORDERED and DECIDED that there is no deficiency in income tax due from petitioner for the taxable year 2019.