Opinion
12726-23S
06-05-2024
KENNETH ROBSON & BEVERLY L. ROBSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 3, 2024, the parties filed a Proposed Stipulated Decision and a Settlement Stipulation. However, the Proposed Stipulated Decision references an I.R.C. section 6662(a) accuracy-related penalty for the taxable year 2020. No penalty was determined in the notice of deficiency for 2020, and respondent did not affirmatively assert a penalty for that year in the Answer. Thus, no penalty appears to be at issue in this case for 2020, and the Court is consequently unable to process the Proposed Stipulated Decision.
That being so, it is
ORDERED that the parties' 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 June 26, 2024, the parties shall file a revised Proposed Stipulated Decision and Settlement Stipulation.