Opinion
15675-12 15751-12
07-17-2023
ROBERT A. DI GIORGIO, SR., ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
On July 11, 2023, the Commissioner filed a Computation for Entry of Decision in which he set forth his calculations to determine the amounts to be entered as decisions in these cases. On that same date, Mr. DiGiorgio filed a document captioned "Petitioner's objection to computation of tax." In that document, Mr. DiGiorgio sets forth new issues, new arguments as to issues the Court already decided, and old arguments the Court already rejected.
In the absence of agreement as to the computations, each party is to submit its own computation of the amount believed by the party to be in accordance with the Court's findings and conclusions. Rule 155(b). Mr. DiGiorgio did not submit a computation, but we will provide him another opportunity to do so. We remind him that his computation is to "be confined strictly to consideration of the correct computation of the amount to be included in the decision resulting from the findings and conclusions made by the Court, and no argument will be heard upon or consideration given to the issues or matters disposed of by the Court's findings and conclusions or to any new issues." Rule 155(c).
Accordingly, it is
ORDERED that Mr. DiGiorgio shall file his alternative computation, if any, by August 18, 2023.