Opinion
5890-22S
01-27-2023
PAUL D. LAYTON & REBECCA D. LAYTON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
On January 25, 2023, petitioners electronically filed documents titled as "Stipulation of Settlement" (Doc. 8) and "Brief in Support of Stipulation of Settlement" (Doc. 9). The documents are in the nature of a Motion to Dismiss.
Upon due consideration and for cause, it is
ORDERED that petitioners' above-referenced stipulation (Doc. 8) and brief (Doc. 9) filed January 25, 2023, are recharacterized as petitioners' "Motion to Dismiss" and "Exhibit to Motion to Dismiss", respectively. It is further
ORDERED that on or before February 24, 2023, respondent shall file a response to petitioners' Motion to Dismiss, or in the alternative, the parties shall electronically file a proposed stipulated decision.