Opinion
21494-21S
11-29-2022
CHANDELL STONE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge
On November 28, 2022, the parties filed a Joint Proposed Stipulated Decision. Upon review of the proposed decision, the Court notes that the Proposed Stipulated Decision fails to address a section 6651(a)(1) Failure to File penalty that is in the Notice of Deficiency. Therefore, the Proposed Stipulated Decision is erroneous, and we will strike it.
Upon due consideration and for cause, it is hereby:
ORDERED that the parties' Joint Proposed Stipulated Decision, filed November 28, 2022, is hereby deemed stricken from the Court's record in this case. It is further
OREDERED that on or before December 7, 2022, the parties shall file a corrected Proposed Stipulated Decision addressing all issues and penalties set forth in the Notice of Deficiency upon which this case is based.