Opinion
36484-21
11-09-2022
NICOLAS WILLIAM MORALES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On November 7, 2022, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, the Court notes that the proposed decision document does not address petitioners' liability, if any, for the I.R.C. section 6662(a) accuracy related penalty determined in the Notice of Deficiency upon which this case is based. Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
For cause, it is
ORDERED that the parties' Proposed Stipulated Decision is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before December 7, 2022, the parties shall file a revised proposed stipulated decision.