Opinion
10392-22
07-26-2024
JULIE CONTRERAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 19, 2024, the parties filed a Proposed Stipulated Decision. However, the proposed decision document makes multiple, repeated references to a "penalty under I.R.C. 6684(c)(2)." Upon review of I.R.C. section 6684, there do not appear to be any subsections thereunder, and the Court is unable to identify any other statutory basis for a "penalty under I.R.C. 6684(c)(2)." That being so, it is
ORDERED that, on or before August 26, 2024, the parties shall file either a revised proposed stipulated decision or a joint report identifying the statutory basis for a "penalty under I.R.C. 6684(c)(2)."