Opinion
5751-24
07-24-2024
ROBERT RAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 22, 2024, the parties filed a Proposed Stipulated Decision and Settlement Stipulation. However, the Court is unable to reconcile these filings. Although the Proposed Stipulated Decision states that there is due to petitioner an overpayment for which amount a claim for refund was filed on April 15, 2022, the Settlement Stipulation states that such claim for refund was filed on October 15, 2022. In view of this inconsistency, the Court is unable to enter the proposed decision document. See I.R.C. § 6512(b)(3).
Upon due consideration and for cause, it is
ORDERED that the above-referenced Proposed Stipulated Decision and Settlement Stipulation are deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before August 26, 2024, the parties shall file a revised proposed stipulated decision and/or settlement stipulation, as appropriate.