Opinion
6130-23
11-22-2023
ALAN G. CYPERT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 20, 2023, petitioner filed in the above-docketed matter a document under the designation "Revised Computation". However, the underlying material is not in the nature of a computation, which would not be procedurally relevant at this juncture, nor does it otherwise appear to comport with any proper type of motion recognized for purposes of the Tax Court Rules of Practice and Procedure. It seems to represent an attempt by petitioner have the taxable years 2013 and 2014 reconsidered and/or considered through the vehicle of the instant case.
The year 2014 were the subject of an earlier proceeding at Docket No. 25040-18, and a stipulated decision was entered in that case on November 17, 2020. That decision is now final, and there is no basis on which it may be reconsidered via the unrelated deficiency notice for 2018 that is before the Court in this case. Likewise, there is no indication of any notice of deficiency or determination for 2013 that should be considered before the Court on the basis of this litigation instigated on April 5, 2023. Contrary to petitioner's apparent view, the Court is not able to address matters randomly simply because they may pertain to taxes.
The premises considered, it is
ORDERED that the document filed November 20, 2023, by petitioner at Docket Index No. 11 is hereby deemed stricken from the Court's record in this case.