Opinion
1108-22
02-27-2023
ALLEN R. GRANT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge.
On February 17, 2023, the parties filed a Proposed Stipulated Decision (Doc. 12). The Proposed Stipulated Decision failed to address the substantial tax understatement penalty determined in the notice of deficiency upon which the case is based. Upon due consideration, it is hereby
ORDERED that the parties' Proposed Stipulated Decision filed February 17, 2023, is stricken from the record in this case. It is further
ORDERED that, on or before March 13, 2023, the parties shall file a Proposed Stipulated Decision.