Opinion
21250-22L
10-20-2023
JOHN KEVIN MCVAY & JULISUE MCVAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On October 18, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. Prior to entry of such stipulated decision, however, it is advisable to ensure that the record herein is complete insofar as concerns the documentation (1) relevant to establish the Court's jurisdiction over all parties and taxable periods and/or (2) referenced in the decision. Here, the Proposed Stipulated Decision references a supplemental notice of determination concerning collection issued "around September 26, 2023". Conversely, the sole copy of such notice in the record was dated and was attached to a status report filed September 1, 2023, that described the notice as issued "around August 7, 2023". Accordingly, upon due consideration, it is
ORDERED that, on or before November 9, 2023, respondent shall file a report and shall attach thereto a dated copy of the supplemental notice of determination for 2018 issued to and/or other documentation clarifying the discrepancy regarding the date of issuance. Appropriate action will then be taken with respect to the stipulated decision received.