Opinion
13891-23S
05-02-2024
EHSAN A. DANESH & ROJA DANESH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Zachary S. Fried, Special Trial Judge
This case for the redetermination of a deficiency is before the Court on respondent's Motion for Entry of Decision, filed March 21, 2024, and heard on April 29, 2024, when the case was called from the calendar for trial during the Philadelphia, Pennsylvania trial session of the Court. Counsel for respondent appeared and argued in support of the motion. There was no appearance by or on behalf of petitioner.
According to respondent's Motion for Entry of Decision, the proposed stipulated decision attached to the motion reflects the basis of settlement agreed upon between the parties. That document, apparently prepared by respondent but unsigned by either petitioner, in and of itself, does little more than suggest respondent's willingness to settle this case for the redetermination of a deficiency for the amounts shown in the document. Without more, the document unsigned by either petitioner is insufficient to support the relief sought in respondent's motion.
Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceeding, it is
ORDERED that respondent's Motion for Entry of Decision is denied. It is further
ORDERED that, on or before May 29, 2024, the parties shall either submit to the Court a proposed stipulated decision or respondent shall file an appropriate motion. It is further
ORDERED that on the Court's own motion, this case is continued with jurisdiction retained by the undersigned.