Opinion
12421-21S
05-15-2023
ROBERT S. STACHURA & ALICIA L. STACHURA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE.
On May 11, 2023, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. That decision was premised on a Settlement Stipulation filed the same date establishing an overpayment for the underlying 2017 taxable year. However, review shows that language in the Proposed Stipulated Decision explaining the source of the underpayment is inconsistent with the explanation therefor provided in the Settlement Stipulation. For example, only a portion of amount was paid on the referenced April 15, 2021, date, and such date is after the mailing of the notice of deficiency.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed May 11, 2023, are hereby deemed stricken from the Court's record in this case.