Opinion
18976-22S
05-09-2023
STEPHEN MARK SIIRTOLA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 4, 2023, the parties filed in the above-docketed matter a Proposed Stipulated Decision for the Court's consideration. Among other things, the proposed decision document determines "that there is no penalty under I.R.C. section 6662(a) due from petitioner for taxable year 2020." The Court notes that, although the proposed decision document references an I.R.C. section 6662(a) penalty, no such penalty appears to be at issue in this case. The Notice of Deficiency upon which this case is based did not determine that petitioner was liable for an I.R.C. section 6662(a) penalty, and respondent did not affirmatively assert such a penalty in the Answer.
In view of the foregoing, the Court is unable to process the parties' Proposed Stipulated Decision.
Accordingly, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision, filed May 4, 2023, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before May 26, 2023, the parties shall file a revised proposed stipulated decision.