Opinion
14774-23
04-18-2024
SHANEKA SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 16, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. That decision was premised on a Stipulation of Settlement filed the same date establishing an overpayment for the underlying 2021 taxable year. However, review shows that the Settlement Stipulation fails to comply with Rule 23(a)(3) of the Tax Court Rules of Practice and Procedure, insofar as the parties' (here, respondent's) contact information is not included. The parties are reminded that Settlement Statements are not considered decision documents for purposes of Rule 23(a)(4) of the Tax Court Rules of Practice and Procedure.
The premises considered, and for cause, it is
ORDERED that the Stipulation of Settlement, filed April 16, 2024, hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before May 8, 2024, the parties shall file a revised Settlement Statement.