Opinion
8510-21
03-08-2022
Ryan Patrick Casey Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On February 25, 2022, 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 2017 taxable year. However, review shows that the Proposed Stipulated Decision fails to address the addition to tax pursuant to section 6654(a) of the Internal Revenue Code reflected on notice of deficiency.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed February 25, 2022, are hereby deemed stricken from the Court's record in this case.