Opinion
2406-23
04-11-2024
ANTHONY REGINELLI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 9, 2024, the parties filed a Proposed Stipulated Decision and a Settlement Stipulation. Because of errors and discrepancies contained in the proposed decision document, the Court is unable to enter it.
Specifically, the heading on the second and third pages of the Proposed Stipulated Decision contains an incorrect docket number. Additionally, the Settlement Stipulation provides that the notice of deficiency was issued to petitioner on April 24, 2023, but the notice of deficiency attached to the Petition is dated December 1, 2022. Further, while petitioner's overpayment for tax year 2017 is written as $5,386.18 on the Settlement Stipulation, it is written as $5,386.16 on the Proposed Stipulated Decision.
Upon due consideration, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before May 2, 2024, the parties shall file revised decision documents for the Court's consideration.