Opinion
6446-19L
12-03-2021
Wendell C. Robinson & May T. Jung-Robinson Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson Judge
On December 2, 2021, the Court held a telephone conference with the parties, during which the Court urged the filing of a stipulation in compliance with Rule 91(a) (1). Respondent's counsel stated he would file a stipulation. Immediately after the phone conference, petitioners filed what purports to be a stipulation (Doc. 77), but it does not include any of the 29 exhibits that are the principal subject of the purported stipulation. Thereafter, respondent filed an equivalent stipulation (Doc. 78), styled as a "Second" stipulation, but with the exhibits attached. It is therefore
ORDERED that the purported stipulation (Doc. 77) filed by petitioners is hereby deemed stricken. It is further
ORDERED that the Clerk of the Court shall recharacterize respondent's filing (Doc. 78) as "First Stipulation of Facts".