Opinion
3850-23
05-10-2023
JAMES JON MILLER & BRITTNEY LAUREN FRANK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 9, 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 underlying 2020 taxable year. However, review shows that the decision fails to address an accuracy-related penalty reflected on the notice of deficiency for 2020 on which the instant proceeding is based.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed May 9, 2023, are hereby deemed stricken from the Court's record in this case.