Opinion
23823-21S
01-05-2022
Mark Phillip Pilja Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
MAURICE B. FOLEY CHIEF JUDGE
On January 4, 2022, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. However, review shows that the decision incorporates matters concerning assessment and payment prior to the intended judicial signature, whereas such issues should be addressed in stipulations following the intended judicial signature or in a separate settlement stipulation. Additionally, the decision references a deficiency in excess of the amount reflected in the underlying notice of deficiency for the taxable year 2018, and no such increased deficiency has been properly stipulated or otherwise pled.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed January 4, 2022, is hereby deemed stricken from the Court's record in this case.