Opinion
7294-21S
11-17-2021
Ronald E. Stidham & Lisa R. Stidham Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On November 15, 2021, the parties filed a proposed stipulated decision for the Court's consideration. Among other things, the proposed decision states that an I.R.C. section 6662(a) accuracy-related penalty in the amount of $672.00 is due from petitioners for the 2017 taxable year. However, upon review of the record, the Court notes that in the answer, filed June 30, 2021, respondent states the following at paragraph five: "Respondent is conceding the accuracy penalty under I.R.C. § 6662(a) shown in the notice of deficiency and in the March 22, 2021, CP2000."
Upon due consideration of the foregoing, it is
ORDERED that, on or before December 1, 2021, respondent shall file a response and shall explain therein the imposition of the I.R.C. section 6662(a) accuracy-related penalty in the parties' proposed stipulated decision, notwithstanding respondent's concession of that penalty in the answer. It is further
ORDERED that action on the parties' proposed stipulated decision shall be held in abeyance pending the filing of respondent's response to this Order.