Opinion
3708-21S
04-26-2023
STEPHANIE R. PINKARD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
On April 19, 2023, the parties filed a Proposed Stipulated Decision. Upon review of the proposed decision, the Court notes the proposed decision is improper in that it references I.R.C. § 6651(a)(2), instead of I.R.C. § 6651(a)(1) as stated in the Notice of Deficiency. Upon due consideration, it is
ORDERED that the Proposed Stipulated Decision, filed April 19, 2023, is stricken from the Court's record in this case. It is further
ORDERED that, on or before May 8, 2023, the parties shall submit to the Court a revised Proposed Stipulated Decision.