Opinion
32298-21S
09-26-2023
AMANDA N. MARTINEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 22, 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 2017 taxable year. However, review shows that the amounts for the accuracy-related penalty shown on the Proposed Stipulated Decision and the Settlement Stipulation for 2017 are inconsistent. Additionally, the date given on the Settlement Stipulation for the mailing of the underlying notice of deficiency does not correspond with that of the copy in the record.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed September 22, 2023, are hereby deemed stricken from the Court's record in this case.