Opinion
22344-22
04-23-2024
MARK D. SCHALL & YAN L. SCHALL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 23, 2024, the parties filed a Proposed Stipulated Decision and a Settlement Stipulation. In the Settlement Stipulation, the parties' counsels' signature blocks fail to include the contact information required by Rule 23(a)(3) of the Tax Court Rules of Practice and Procedure.
Further, the Statement of Account attached to the Settlement Stipulation has inconsistencies with the Proposed Stipulated Decision. Specifically, the Statement of Account provides a different amount for the overpayment, and it lacks information regarding petitioners' claim for refund, the mailing of the notice of deficiency, and the penalty.
Upon due consideration, it is
ORDERED that the above-referenced Settlement Stipulation is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before May 15, 2024, the parties shall file a revised settlement stipulation. Appropriate action will then be taken with respect to the above-referenced Proposed Stipulated Decision.