Opinion
30853-21S
09-30-2022
STEPHEN M. GOLDSTEIN & IIANA GOLDSTEIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Pending in the above-docked matter is a Motion for Entry of Decision and first supplement thereto, filed January 10, 2022, by petitioners herein. Subsequently, on June 22, 2022, respondent filed a response in objection, asking that the parties instead be permitted time for the parties to submit a Proposed Stipulated Decision. A Proposed Stipulated Decision then followed on July 26, 2022, but such decision referenced an accuracy-related penalty for the 2018 year that was not reflected on the underlying notice of deficiency or otherwise pled by respondent. Given that discrepancy, the decision was stricken from the record by an Order served August 1, 2022.
Most recently, on September 28, 2022, respondent filed a status report advising that efforts to prepare a corrected decision were in process and requesting additional time.
The premises considered, it is
ORDERED that, on or before October 31, 2022, the parties shall submit a corrected Proposed Stipulated Decision resolving this case and incorporating, if applicable, appropriate language establishing petitioners' entitlement to any overpayment.