Opinion
37409-21
01-05-2023
JOE J. HOLLOWAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 3, 2023, the parties filed a settlement stipulation and a proposed stipulated decision for the Court's consideration. A review of those documents discloses that the settlement statement includes an incorrect date for the mailing of the notice of deficiency on which this case is based and the proposed stipulated decision fails to address the penalty under I.R.C. section 6662(a) set forth in the notice of deficiency.
Accordingly, upon due consideration, it is
ORDERED that the above-described settlement stipulation and proposed stipulated decision are deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before February 3, 2023, the parties shall file revised proposed decision documents for the Court's consideration.