Opinion
6096-22SL
01-23-2024
JAMIE L. PETTUS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Zachary S. Fried Special Trial Judge
On January 16, 2024, the parties filed a Proposed Stipulated Decision for the Court's consideration. Upon review thereof, the Court notes that the proposed decision does not address petitioner's underlying liability for 2013 above the intended judicial signature. Rather, the parties' agreement as to that underlying liability appears only in a stipulation set forth below the intended judicial signature. In collection cases where the underlying liability is at issue, as here, the determination as to the taxpayer's liability, if any, for the taxable year at issue must appear in the Court's decision. That being so, the Court is unable to process the parties' Proposed Stipulated Decision.
Upon due consideration, it is
ORDERED that the above-described Proposed Stipulated Decision is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before February 16, 2024, the parties shall file a revised proposed stipulated decision for the Court's consideration.