Opinion
15876-23S
12-05-2023
KATRINA N. LABAUT & ROBERT L. LABAUT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On November 30, 2023, the parties filed a Proposed Stipulated Decision resolving this litigation. Upon further review, it appears that the record does not contain a copy of any notice challenged by petitioners in this case. In addition, it appears that while petitioners indicated in the Petition that they were challenging a notice of determination regarding collection action, the decision document addresses a deficiency.
Accordingly, upon due consideration, it is
ORDERED that, on or before January 2, 2024, respondent shall file a Response to this Order and attach thereto a complete copy of the notice of deficiency, or other notice, on which this case is based.