Opinion
32935-21S
03-22-2022
Trevor P. Ruff Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On February 4, 2022, the parties filed a proposed stipulated decision. Upon review, the Court notes that the proposed decision is improper in that it incorporates matters concerning assessment and refund above the intended judicial signature, rather than in stipulations following such intended signature or in a separate settlement stipulation.
In view of the foregoing, it is
ORDERED that the parties' proposed stipulated decision, filed February 4, 2022, is recharacterized as a settlement stipulation. It is further
ORDERED that, on or before April 22, 2022, either (1) the parties shall file a proper proposed stipulated decision, or (2) respondent shall file an appropriate motion for entry of decision.