Opinion
4635-21
07-05-2022
REGINALD RICARDO FENN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
L. Paige Marvel Judge
On June 27, 2022, the parties submitted to the Court a proposed stipulated decision. The proposed stipulated decision failed to address the I.R.C. section 6654 addition to tax determined in the November 2, 2020, notice of deficiency upon which this case is based. A member of the Court's staff spoke with respondent's counsel on June 27, 2022, regarding the decision document and was informed that a corrected decision document would be filed. On June 30, 2022, the parties submitted another proposed stipulated decision that corrects the I.R.C. section 6654 issue, but the proposed stipulated decision appears to bear an electronic signature for petitioner. The Court will strike from the record both decision documents filed June 27 and June. 30, 2022, and permit additional time for the parties to file a properly executed proposed stipulated decision. Accordingly, it is
ORDERED that the parties' proposed stipulated decision, filed June 27, 2022, is hereby stricken from the Court's record. It is further
ORDERED that the parties' proposed stipulated decision, filed June 30, 2022, is hereby stricken from the Court's record. It is further
ORDERED that on or before August 4, 2022, the parties shall file a proposed stipulated decision.