Opinion
35891-218
10-24-2022
BRENDAN CELESTE KELLEHER & FLORINA CRISTINA KELLEHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE
On October 20, 2022, the parties filed a Proposed Stipulated Decision. Among other things, that proposed decision document determines an overpayment in tax of 2,319.23 is due to petitioners for tax year 2018. However, the record does not establish whether the Court has jurisdiction to find whether petitioners are entitled to such an overpayment for that year. Sec. 6512(b)(1). (3). In view of the foregoing, it is
ORDERED that, on or before November 11, 2022, respondent shall file a Response to this order.