Opinion
13300-21
10-18-2022
ARI PAUL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On October 12, 2022, 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 2018 taxable year. However, review shows that the Proposed Stipulated Decision and Settlement Stipulation reflect increased amounts for the deficiency and various additions to tax in excess of those determined in the notice of deficiency for 2018 which have not been properly pled or otherwise explicitly stipulated by the parties (e.g., as stipulations of the increased amounts incorporated in the Proposed Stipulated Decision below the judicial signature).
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed October 12, 2022, are hereby deemed stricken from the Court's record in this case.