Opinion
13289-22S
03-21-2023
JOSEPH M. ROACH Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
This case is calendared for trial at the April 11, 2023, San Antonio, Texas, Trial Session of the Court.
On March 20, 2023, the parties filed a Proposed Stipulated Decision. Upon review of the proposed decision, the Court notes that the parties did not address the addition to tax under the provisions of I.R.C. § 6654 asserted in the notice of deficiency at issue here. We will strike the proposed stipulated decision and order the parties to refile a new proposed stipulated decision consistent with the notice of deficiency. For cause, it is
ORDERED that the Proposed Stipulated Decision, filed March 20, 2023, is hereby stricken from the Court's record in this case. It is further
ORDERED that, on or before April 11, 2023, the parties shall file a revised Proposed Stipulated Decision.