Opinion
9874-23S
05-07-2024
ORDER
Kathleen Kerrigan Chief Judge
On May 7, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. However, review shows that the decision provides for an overpayment, yet it neither references nor incorporate facts from a stipulation by the parties, nor was a proper Settlement Stipulation filed. Such fails to satisfy the requirements of the Internal Revenue Code in connection with the determination of an overpayment.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed May 7, 2024, is hereby deemed stricken from the Court's record in this case.