Opinion
472-23
03-07-2024
SCOTT LESLIE ADAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Travis A. Greaves Judge
On January 2, 2024, respondent filed a Motion to Dismiss for Failure to Properly Prosecute.
This case was called from the calendar during the Court's January 08, 2024, Jacksonville, Florida trial session. There was no appearance by or on behalf of the petitioner. Counsel for respondent appeared and was heard.
On January 19, 2024, the Court ordered petitioner to show cause, on or before February 12, 2024, why respondent's Motion to Dismiss for Failure to Properly Prosecute should not be granted, and a decision entered in this case. As of the date of this Order of Dismissal and Decision, no response has been received by or on behalf of petitioner.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Failure to Properly Prosecute, filed January 2, 2024, is granted, and this case is dismissed for failure to properly prosecute. It is further
ORDERED that the Court's Order to Show Cause, served January 19, 2024, is made absolute. It is further
ORDERED and DECIDED that there are deficiencies in income tax due from petitioner for the taxable years 2016 and 2017 in the amounts of $513,035.00 and $394,472.00, respectively; and
That there are additions to tax under the provisions of I.R.C. section 6651(f) due from petitioner for the taxable years 2016 and 2017 in the amounts of $369,649.95 and $282,103.30, respectively; and
That there are additions to tax under the provisions of I.R.C. section 6651(a)(2) due from petitioner for the taxable years 2016 and 2017 in the amounts of $127,465.50 and $97,277.00, respectively; and
That there are additions to tax under the provisions of I.R.C. section 6654 due from petitioner for the taxable years 2016 and 2017 in the amounts of $12,179.49 and $9,301.93, respectively.