Opinion
15944-21L
12-14-2021
Lawrence Thompson Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
The petition in this case was filed in response to a notice of determination sustaining a proposed levy to collect petitioner's unpaid Federal income tax liability for the 2018 taxable year. On December 8, 2021, the parties filed a proposed stipulated decision for the Court's consideration. Upon review thereof, the Court notes that the proposed decision states that the notice of determination "is sustained, except as provided herein." (Emphasis added.) The exceptions or modifications, if any, to which this quoted statement may refer are not clear to the Court, insofar as no further information appears above the intended judicial signature of the proposed decision. Moreover, the substantive information appearing below the intended judicial signature of the proposed decision pertains to the taxable years 2015, 2016, and 2017: Those years are not before the Court in this matter. As noted, this case concerns an unpaid tax liability for 2018. In view of the foregoing, the Court is unable to process the parties' proposed stipulated decision.
Accordingly, and for cause, it is
ORDERED that the parties' proposed stipulated decision, filed December 8, 2021, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before January 13, 2022, the parties shall file a revised proposed stipulated decision.