Opinion
11606-22S
10-16-2023
MATTHEW B. LUN & MARNI D. LUN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 29, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. That decision was premised on a Settlement Stipulation filed the same date establishing an overpayment for the underlying 2019 taxable year. However, review shows that the proposed decision fails to address an accuracy-related penalty reflected on the notice of deficiency for 2019 on which the instant proceeding is based.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed September 29, 2023, is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before November 3, 2023, the parties shall file a revised proposed stipulated decision for the Court's consideration.