Opinion
2924-22
09-13-2022
DANIEL E. SACH & CHRISTINA SACH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On September 7, 2022, the parties filed a Proposed Stipulated Decision. However, the Court notes that the proposed decision document does not address petitioners' liability, if any, for the I.R.C. section 6651(a)(2) addition to tax for 2018 determined in the Notice of Deficiency upon which this case is based. Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
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 October 4, 2022, the parties shall file a revised proposed stipulated decision.