Opinion
30156-21
10-30-2023
ADAM D. PERKINS & SHELBY J. PERKINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge.
On October 23, 2023, the parties filed a proposed stipulated decision in this case. However, a review of the record shows that the proposed stipulated decision reflects deficiencies for taxable years 2014 and 2016 in excess of that determined in the Notice of Deficiency, dated June 4, 2021. The addition to tax under I.R.C. section 6654 is also in excess of that determined in the Notice of Deficiency. The increased amounts have not been explicitly pled or stipulated. Premises considered, it is
ORDERED that the parties proposed stipulated decision, filed October 23, 2023, is hereby stricken from the record in this case. It is further
ORDERED that the parties shall, on or before November 30, 2023, file with the Court a corrected proposed stipulated decision, or in lieu thereof, a joint report or separate reports as to the then present status of this case.