Opinion
1683-23S
09-28-2023
DAVID MICHAEL MILES & BETTY JOSEPHINE MILES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
This case is calendared for trial at the December 18, 2023, Dallas, Texas, Trial Session of the Court.
On September 26, 2023, the parties filed a Proposed Stipulated Decision. Upon review, it appears that the decision references an accuracy-related penalty under I.R.C. § 6662(a), that is not reflected in the notice of deficiency dated November 21, 2022. Accordingly, the Court will strike the proposed stipulated decision.
Upon due consideration and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision filed September 26, 2023, is hereby stricken from the Court's record and shall not be viewable as part of this case.