Opinion
5134-22S
07-25-2022
ABRAHAM K. GEORGE & LIZY GEORGE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 30, 2022, the Court filed a Letter by petitioners dated March 22, 2022. Therein, petitioners state that the parties have reached an agreement regarding the underlying tax liability at issue, and request that the Court "close the tax petition."
In a deficiency case where this Court has jurisdiction, as here, the Court is generally required to enter a decision specifying the amount of the deficiency, if any, for the taxable year at issue. See I.R.C. § 7459(d); Estate of Ming v. Commissioner, 62 T.C. 519 (1974). Thus, even if the parties have reached a settlement, as it appears may have occurred in this case, the Court must enter a decision. Accordingly, we will recharacterize petitioners' Letter and direct the parties as set forth below.
Upon due consideration of the foregoing, it is
ORDERED that petitioners' above-referenced Letter is recharacterized as petitioners' Motion for Entry of Decision. It is further
ORDERED that, on or before August 24, 2022, respondent shall file a response to petitioners' Motion for Entry of Decision, or the parties shall file a proposed stipulated decision.