Opinion
34270-21S
01-08-2024
ORDER
Kathleen Kerrigan Chief Judge
On January 3, 2024, the parties filed a Settlement Stipulation and Proposed Stipulated Decision for the Court's consideration. The Proposed Stipulated Decision reflects a greater deficiency than that set forth in the notice of deficiency on which this case is based. Respondent did not assert an increased deficiency in his Answer to the Petition and nothing below the judicial signature line in the Proposed Stipulated Decision accounts for the increase. Furthermore, there is a discrepancy between the amount of the deficiency reflected in the Proposed Stipulated Decision and that reflected in the IRS Statement of Account attached to the parties' Settlement Stipulation.
Upon due consideration of the foregoing and for cause, it is
ORDERED that the above-referenced Settlement Stipulation and Proposed Stipulated Decision are deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before January 29, 2024, the parties shall file revised decision documents for the Court's consideration.