Opinion
16794-23
12-05-2023
RAFIK Y. KAMELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On November 21, 2023, the parties filed a Proposed Stipulated Decision and a Settlement Stipulation. Among other stipulations, the parties state: "It is further stipulated that the court lacks jurisdiction over tax year 2019 on the ground the notice of deficiency did not determine a deficiency for tax year 2019." However, the parties have filed no jurisdictional motion as to tax year 2019. The proposed decision documents thus appear to be premature.
Upon due consideration, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, filed November 21, 2023, are deemed stricken from the record.