Opinion
27284-22
03-27-2024
PAUL L. LONDON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Elizabeth A. Copeland Judge
This Order requires Petitioner, Paul L. London, to respond in writing by April 5, 2024.
This case is calendared for trial at the Trial Session of the Court scheduled to commence on April 8, 2024, at the Alexander Hamilton U.S. Custom House, located at One Bowling Green, Courtroom #610, 6th Floor in New York, New York 10004.
On March 15, 2024, Respondent filed with the Court a Motion to Dismiss for Lack of Prosecution. Respondent is asking the Court to find that there is no deficiency in income tax due from Petitioner Paul L. London for taxable year 2020, and there is no penalty to tax under I.R.C. § 6662 due from Petitioner for taxable year 2020. Respondent informed the Court that this amount is less than the amount listed in the Notice of Deficiency, dated September 6, 2022, due to concessions. Respondent informed the Court that Petitioner reached a settlement and decision documents were prepared and mailed. Respondent informed the Court that since the mailing of decision documents, on or about January 18, 2024, Petitioner has been unresponsive.
Mr. London is encouraged to contact the low-income taxpayer clinic in his locale for assistance in responding to this motion, namely: Legal Services of New Jersey at (888) 576-5529; Northeast New Jersey Legal Services at (201) 792-6363; and Rutgers School of Law Federal Tax Clinic at (973) 353-1685.
Upon due consideration, and for cause, it is
ORDERED that, on or before April 5, 2024, Petitioner Paul L. London shall file with the Court a written response as to why Respondent's Motion to Dismiss for Lack of Prosecution should not be granted and why the Court should not enter a decision determining that there is no deficiency in income tax due from Petitioner Paul L. London for taxable year 2020, and there is no penalty to tax under I.R.C. § 6662 due from Petitioner for taxable year 2020. It is further
ORDERED that Respondent's Motion to Dismiss for Lack of Prosecution, filed with the Court on March 15, 2024, is set for hearing at the calendar call on April 8, 2024, at 10:00 a.m. ET, during the Court's New York, New York Trial Session. Petitioner is advised that failure to appear at the hearing on April 8, 2024, may result in the Court granting Respondent's motion and entering an order and decision against Petitioner.