Opinion
37053-21
07-12-2023
ANTHONY MICHAEL HINOJOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge.
On July 11, 2023, the parties filed with the Court a proposed stipulated decision in this case. The proposed decision references a penalty pursuant to I.R.C. section 6662(a), however, the Notice of Deficiency issued to petitioner on October 4, 2021, and attached to the petition in this case, asserts a penalty pursuant to I.R.C. section 6676. The Court also notes that respondent has conceded this penalty. Premises considered, it is
ORDERED that the proposed stipulated decision, filed July 11, 2023, is hereby stricken from the record in this case. It is further
ORDERED that the parties shall, on or before August 10, 2023, file with the court a corrected proposed stipulated decision that addresses the I.R.C. section 6676 penalty.