Opinion
15089-22
08-28-2024
SAMUEL KEIN & CHAYA S. KEIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 24, 2022, petitioners filed the Petition in this case, seeking review of notices of deficiency issued for their 2018 and 2019 tax years. Petitioners attached to the Petition copies of the relevant notices of deficiency.
On August 23, 2024, the parties filed a Proposed Stipulated Decision which addresses only petitioners' 2018 tax year. On August 26, 2024, the Court issued an Order to Show Cause directing the parties to show cause why the Court should not issue and Order striking the Proposed Stipulated Decision filed August 23, 2024, as it failed to address all of the tax years at issue in this case. In response, on August 27, 2024, the parties filed another Proposed Stipulated Decision which addresses only petitioner Samuel Kein's 2019 tax year. Both just-described Proposed Stipulated Decisions are improper because the Court can enter only one Decision concluding a case and neither Proposed Stipulated Decision addresses all of the tax years at issue in this case.
Upon due consideration, it is
ORDERED that the Court's Order to Show Cause, issued August 26, 2024, is hereby made absolute. It is further
ORDERED that the Proposed Stipulated Decision, filed August 23, 2024, and the Proposed Stipulated Decision, filed August 27, 2024, are deemed stricken from the Court's record in this case.