Opinion
3524-22S
11-14-2022
BONGI G. LICORISH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On November 10, 2022, the parties filed a Settlement Stipulation and a revised Proposed Stipulated Decision. However, upon review of the former, the Court notes that the Settlement Stipulation appears to be a duplicate of the Settlement Stipulation filed October 11, 2022, at Docket Index No. 5. Upon review of the latter, the Court notes that the proposed decision document references an I.R.C. section 6662(a) penalty. Conversely, the underlying Notice of Deficiency upon which this case is based does not. Moreover, the Court notes that the proposed decision document does not address petitioner's liability, if any, for the I.R.C. section 6676 penalty determined in the Notice of Deficiency.
The premises considered and for cause, it is
ORDERED that the parties' Settlement Stipulation, filed October 11, 2022, and Proposed Stipulated Decision, filed November 10, 2022, are hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before December 5, 2022, the parties shall file a revised proposed stipulated decision.