Opinion
27822-22
08-08-2024
MICHAEL POTOPEA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
On August 2, 2024, the parties filed a Proposed Stipulated Decision. The document twice mentions an addition to tax under I.R.C. sec. 6651(a)(2) as follows:
That there is an addition to tax due from petitioner for the taxable year 2018, under the provisions of I.R.C. § 665l(a)(2), in the amount of $1,746.90; [and]
That there is an addition to tax due from petitioner for the taxable year 2018, under the provisions of I.R.C. § 6651(a)(2), in the amount of $1,941.
Because the Proposed Stipulated Decision is unclear as to the correct amount of addition to tax due from petitioner under §6651(a)(2), and is also unclear as to whether any amount of addition to tax is due under § 6651(a)(1), it is
ORDERED that the parties' Proposed Stipulated Decision (Doc. 30) is stricken from the record.