Opinion
19473-23S
06-11-2024
CHARLES F. GAY & PATRICIA T. ROSS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On June 10, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. That decision was premised on a Settlement Stipulation filed the same date establishing an overpayment for the underlying 2021 taxable year. However, review shows that the while the Proposed Stipulated Decision states that the full amount of the overpayment was paid after the mailing of the notice of deficiency, the amount of the payments so dated after the notice is insufficient to account for the full overpayment.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed June 10, 2024, are hereby deemed stricken from the Court's record in this case.