Opinion
10655-21
08-24-2022
ABRAHAM PUPO DOMINGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 17, 2022, the parties filed a proposed stipulated decision for the Court's consideration. However, that document includes an addition to tax under I.R.C. section 6651(a)(2) that was not proposed in the notice of deficiency on which this case is based. Respondent did not assert such an addition to tax in his answer, and nothing below the signature line of the proposed stipulated decision explains the inclusion of the addition to tax. Accordingly, the Court is unable to process the parties' proposed stipulated decision as submitted.
For cause, it is
ORDERED that the proposed stipulated decision, filed August 17, 2022, is stricken from the Court's record in this case. It is further
ORDERED that, on or before October 17, 2022, the parties shall file a revised proposed stipulated decision.