Opinion
17254-22
05-16-2024
ERNEST D. WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 16, 2024, the parties filed a Proposed Stipulated Decision and a Settlement Stipulation. However, upon review thereof, the Court is unable to reconcile the representations in these documents. Specifically, the Court notes that the Settlement Stipulation concludes that the $89,816.00 overpayment is barred by the statute of limitations. Yet, the Proposed Stipulated Decision appears to conclude otherwise. In view of the foregoing, it is
ORDERED that, on or before June 7, 2024, the parties shall file a joint report and shall address therein the application of I.R.C. sections 6512(b)(3) and 6511(b)(2) to the facts of this case and whether the overpayment in this case is barred by the statute of limitations.