Opinion
26130-22
05-02-2024
RAVISHANKER PATEL & JAYASREE PATEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 1, 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 establishing an overpayment for the underlying 2019 taxable year, one of the years in issue. However, review shows that the Settlement Stipulation fails to comply with Rule 23(a)(3) of the Tax Court Rules of Practice and Procedure, insofar as the parties' contact information is not included. 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.
Additionally, the Proposed Stipulated Decision fails to reference, and to incorporate facts from, the stipulation by the parties.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed May 1, 2024, are hereby deemed stricken from the Court's record in this case.