Opinion
5804-22S
11-09-2023
ORDER
Kathleen Kerrigan Chief Judge.
On October 30, 2023, the parties filed a Settlement Stipulation and Proposed Stipulated Decision. By Order served November 2, 2023, the Court directed that those filings be deemed stricken from the record on the ground that the signature blocks of the documents did not properly identify the petitioner in this case. The Order also noted an apparent ambiguity in the record regarding the I.R.C. section 6662(a) accuracy-related penalty referenced in the Proposed Stipulated Decision.
On November 8, 2023, respondent filed a Response to the Court's Order. The Response clarifies the record in this case with respect to the status of the accuracy-related penalty.
Upon due consideration and for cause, it is
ORDERED that, on or before December 11, 2023, the parties shall file revised decision documents.