Opinion
12797-23S
09-18-2024
W. SCOTT STANLEY & CINDY C. STANLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case is currently calendared for trial during the Court's Birmingham, Alabama trial session, scheduled to begin October 15, 2024.
On August 20, 2024, the Court received from the parties a proposed stipulated decision purporting to resolve this litigation. After the Court's review, however, it appears to reference penalty provisions, i.e., section 6662(a) and (b)(1), that were not included in the underlying notice of deficiency (which referred to section 6662(b)(2)). We will strike and allow the parties to file a revised stipulated decision.
Accordingly, it is
ORDERED that the joint proposed stipulated decision filed August 20, 2024, is deemed stricken from the Court's record in this case. The parties may re-file a proposed stipulated decision for the Court's consideration.