Opinion
31467-21
11-08-2022
JAY M. CRUIKSHANK & ANNAMARIE J. CRUIKSHANK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 3, 2022, the parties filed a proposed stipulated decision for the Court's consideration. A review of the document discloses that it does not address the section 6662(a) penalty set forth in the notice of deficiency on which this case is based.
Accordingly, upon due consideration, it is
ORDERED that the proposed stipulated decision is stricken from the Court's record in this case. It is further
ORDERED that the parties shall, on or before November 21, 2022, file a revised proposed stipulated decision for the Court's consideration.