Opinion
713-23S
01-02-2024
TERESA C.W. YOUNG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 21 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration. A review of that document discloses that it improperly incorporates references to additions to tax that were not set forth in the notice of deficiency on which this case is based and the parties' stipulations below the intended judicial signature line are insufficient for purposes of §6512(b)(3).
Accordingly, upon due consideration, it is
ORDERED that the above-described Proposed Stipulated Decision is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before January 31, 2024, the parties shall file a revised Proposed Stipulated Decision for the Court's consideration.