Opinion
22372-22
12-08-2023
COLLEEN DALE PEACE & STEVEN J. PEACE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
This case for the redetermination of a deficiency is before the Court on petitioners' motion to vacate filed October 13, 2023. Petitioners' motion is directed to the stipulated decision that was entered on September 11, 2023. A hearing was conducted on petitioners' motion in Jacksonville, Florida, on December 6, 2023, during the trial session that began in that city on December 4, 2023. Neither self-represented petitioner appeared at the hearing; counsel for respondent appeared and was heard.
Petitioners' motion was apparently prompted by (1) a misunderstanding of the deficiency procedures, and (2) concern over the treatment of a payment towards the deficiency. It is clear that the stipulated decision properly accounts for the deficiency as well as the payment.
Premises considered, and for cause appearing more fully in the transcript of the above-referenced proceedings, it is
ORDERED that petitioners' motion is denied.