Opinion
11562-21
07-14-2022
LUIS E. IZQUIERDO & LAUREN K. IZQUIERDO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge
This case is currently calendared on the Court's Atlanta, Georgia, trial session, scheduled to begin September 12, 2022. On June 27, 2022, the parties filed a joint proposed stipulated decision and a stipulation of settlement. Upon review of the proposed stipulated decision, the deficiency amount included therein for petitioners Luis E. and Lauren K. Izquierdo's 2017 tax year is more than the deficiency proposed in the notice of deficiency, dated January 4, 2021, upon which this case is based. The Commissioner did not assert increased amount for tax year 2017 in the answer and nothing in the proposed stipulated decision accounts for the increase.
On July 8, 2022, the parties filed another joint proposed stipulated decision and stipulation of settlement. In this joint proposed stipulated decision, the parties addressed the increased deficiency for tax year 2017. Upon due consideration, it is
ORDERED that the joint proposed stipulated decision and joint stipulation of settlement, filed on June 27, 2022, are hereby stricken from the Court's record.