Opinion
33485-21S
01-11-2023
BARRY A. DIKES & AMY L. DIKES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
ADAM B. LANDY SPECIAL TRIAL JUDGE
On January 10, 2023, the parties filed a Proposed Stipulated Decision (Doc. 9) which did not address the failure-to-pay addition to tax, pursuant to I.R.C. § 6651(a)(1), raised in the Notice of Deficiency, dated July 26, 2021. The Court is therefore unable to process the parties' Proposed Stipulated Decision.
Upon due consideration, it is
ORDERED that the parties' Proposed Stipulated Decision (Doc. 9), filed January 10, 2023, is hereby deemed stricken from the Court's record and shall not be viewable as part of this case. It is further
ORDERED that the parties shall submit a revised Proposed Stipulated Decision or a status report (preferably a joint report) on or before January 31, 2023.