Opinion
8675-22
11-17-2022
JOHN Q. DEVERTER & KELLY M. DEVERTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On November 10, 2022, the parties filed a proposed stipulated decision for the Court's consideration. A review of that document discloses that it does not address a penalty under I.R.C. section 6662(a) that is set forth in the notice of deficiency on which this case is based and includes additions to tax under I.R.C. sections 6651(a)(1) and (a)(2) that do not appear to have been set forth in the notice of deficiency.
Accordingly, upon due consideration, it is
ORDERED that the above-described proposed stipulated decision is stricken from the Court's record in this case. It is further
ORDERED that, on or before December 23, 2022, the parties shall file a revised proposed stipulated decision for the Court's consideration.