Opinion
11499-24
09-23-2024
PRASHANT MATE & PALLAVI MATE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 20, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. That decision was premised on a Settlement Stipulation filed the same date purportedly establishing an overpayment for the underlying 2021 taxable year. However, review shows that the Settlement Stipulation fails to attach the Statement of Account referenced therein reflecting such overpayment.
Additionally, it appears that the Settlement Stipulation fails fully to comply with Rule 23(a)(3) of the Tax Court Rules of Practice and Procedure, insofar as the petitioner Prashant Mate's contact information is not clearly presented. The parties are reminded that Settlement Stipulations are not considered decision documents for purposes of Rule 23(a)(4) of the Tax Court Rules of Practice and Procedure.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed September 20, 2024, are hereby deemed stricken from the Court's record in this case.