Opinion
20781-22
04-09-2024
MICHAEL DARNELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On April 5, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. That decision was premised on a Settlement Stipulation filed the same date purportedly establishing an overpayment for the underlying 2019 taxable year. However, review shows that the Settlement Stipulation fails to comply with Rule 23(a)(3) of the Tax Court Rules of Practice and Procedure, insofar as the parties' contact information is not included. The parties are reminded that Settlement Statements are not considered decision documents for purposes of Rule 23(a)(4) of the Tax Court Rules of Practice and Procedure.
The premises considered, and for cause, it is
ORDERED that the Settlement Stipulation, filed April 5, 2024, hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before April 23, 2024, the parties shall file a revised Settlement Statement.