Opinion
9874-24S
09-27-2024
DONNA ZAIKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On September 27, 2024, the parties filed a Proposed Stipulated Decision. Among other things, the proposed decision document states "that there is no penalties due from the petitioner for the taxable year 2021 under the provisions of I.R.C. § 6651(a)2 and § 6662(a)." [sic] However, no addition to tax under I.R.C. section 6651(a) was determined in the notice of deficiency, and respondent did not affirmatively assert such an addition in the Answer. Thus, no addition to tax appears to be at issue in this case. That being so, it is
ORDERED that the parties' Proposed Stipulated Decision is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before October 30, 2024, the parties shall file an appropriately revised proposed stipulated decision.