CSTJ Zachary S. (“High-Rise”) Fried echoes the words never spoken by Alfonso Bedoya in the 1948 thirty-sixth greatest film of all time to IRS and Lisa K. Jewell in Robert W. Jewell, Deceased & Lisa K. Jewell, Docket No. 11803-24S, filed 10/14/25. IRS moves to toss the petition as to both the late Robert and Lisa.

The late Robert passed post-petition and no fiduciary is appointed to represent him. Hence, CSTJ Fried wants to dismiss the petition as to him for lack of prosecution, nihil obstat.

OTOH, Lisa K. Jewell and IRS proffer a Proposed Stipulated Decision.

This causes procedural indigestion, as “the Court may enter only one decision in any case,” Order, at p. 1. So, to enter the proposed Stip as a decision leaves unresolved the dismissal as to the late Robert. Recharacterizing the Stip Decision as a Stip of Settled Issues still falls short.

CSTJ Fried starts by recharacterizing IRS’ initial motion as a Motion to Dismiss for Lack of Prosecution as to Robert W. Jewell, Deceased, and grants that.

Next, the Proposed Stipulated Decision is deemed stricken from the Court’s record in this case. So what about whatever deal IRS and Lisa K. made?

CSTJ Fried says “(I)n order to give effect to the agreement of the remaining parties, as set forth in that now-stricken document,” Order, at p. 1, there is no deficiency in income tax nor overpayment, and  there is no penalty under I.R.C. section 6662(a).

Who needs stipulated facts or decisions?