Opinion
19999-23S
03-14-2024
JOHN FRANCK & ARGIRO S. FRANCK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On March 14, 2024, the parties filed a Proposed Stipulated Decision in the above-docketed matter. The Proposed Stipulated Decision references a penalty under I.R.C. section 6662(a), but no such penalty was asserted in the notice of deficiency giving rise to this case. Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
Upon due consideration of the foregoing, it is
ORDERED that the above-referenced Proposed Stipulated Decision is deemed stricken from the record in this case. It is further
ORDERED that, on or before April 15, 2024, the parties shall file a revised proposed stipulated decision for the Court's consideration.