Opinion
11084-20S
04-05-2022
BRETT THOMAS MANLOVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Judge
On March 29, 2022, the parties filed a Proposed Stipulated Decision for the Court's consideration. However the addition to tax under I.R.C. section 6651(a)(2) proposed therein for the 2016 tax year, $619.25, is more than the addition to tax determined for that year in the Notice of Deficiency, $483.01. Respondent did not assert an increased addition to tax in the Answer and nothing below the line in the Proposed Stipulated Decision accounts for the increase. Accordingly, the Court is unable to process the parties' Proposed Stipulated Decision.
For cause, it is
ORDERED that the Proposed Stipulated Decision, filed March 29, 2022, is hereby stricken from the Court's record in this case. It is further
ORDERED that the parties shall, on or before May 5, 2022, file a revised Proposed Stipulated Decision.