Opinion
10096-21
09-29-2022
MARY J. LIFORD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge
This case was calendared for a remote trial at the session of the Court scheduled to commence on April 18, 2022, for cases in which Knoxville, Tennessee, was the place of trial. On March 25, 2022, the parties filed a status report, indicating therein that all issues in this case were resolved. On April 11, 2022, the Court issued an order striking this case from the calendar for the remote trial session of the Court commencing April 18, 2022, and directing the parties to file on or before May 5, 2022, a signed proposed stipulated decision or a joint status report. The undersigned retained jurisdiction.
On April 29, 2022, the parties filed a settlement stipulation. In that settlement stipulation, the parties reference an "attached Statement of Account (Form 3623)", however, the parties neglected to attach that Statement of Account to the parties' stipulation. Additionally, on April 29, 2022, the parties filed a signed proposed stipulated decision. The parties' proposed stipulated decision fails to address the deficiency for petitioner's taxable year 2017 as set forth in the notice of deficiency dated January 4, 2021. Accordingly, the parties' settlement stipulation and proposed stipulated decision shall be stricken from the record.
Upon due consideration of the foregoing, it is
ORDERED that the parties' settlement stipulation filed April 29, 2022, at Docket Index 12, is hereby stricken from the record. It is further
ORDERED that the parties' proposed stipulated decision filed April 29, 2022, at Docket Index 13, is hereby stricken from the record. It is further
ORDERED that, on or before November 1, 2022, the parties shall file a revised settlement stipulation and attach thereto any Statement of Account (Form 3623), referenced in that stipulation. It is further
ORDERED that, on or before November 1, 2022, the parties shall file a revised signed proposed stipulated decision that sets forth any deficiency in income tax due from petitioner for taxable year 2017.