Opinion
10181-23S
04-11-2024
ARIEL R. VILLASOL & EMMA A. VILLASOL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 8, 2024, the parties filed a Proposed Stipulated Decision for the Court's consideration. The proposed decision document is premised upon a Settlement Stipulation filed on the same date, reflecting an overpayment for the taxable year
2020.However, although the proposed decision document states that the amount of the overpayment was paid by petitioners on May 17, 2021, the Settlement Stipulation suggests that the amount was instead paid (or deemed paid) on April 15, 2021.In view of the foregoing, the Court is unable to process the Proposed Stipulated Decision. See I.R.C. § 6512(b)(3). That being so, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation are deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before May 13, 2024, the parties shall file revised decision documents.