Opinion
4565-21S
05-17-2022
BORIS A. MIRKIN & SUSANNA MIRKIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge
This case is currently calendared for trial at the Court's New York City, New York trial session, which is scheduled to begin June 13, 2022. On April 4, 2022, the Court served an Order on the parties saying, if the parties do not submit a proposed decision document which states there is not any section 6662(a) penalty due from petitioners for the year in issue before May 13, 2022, then on or before May 13, 2022, respondent shall file a status report attaching thereto any relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy-related penalty under section 6662(a). On May 13, 2022 respondent filed an Status report indicating that he is unable to verify whether he complied with the provisions set forth in I.R.C. § 6751(b)(1) as it relates to the proposed accuracy-related penalties pursuant to I.R.C. § 6662(a) for the tax years at issue. Respondent states that he will continue to investigate and research his records and supplement this status report in the near future. Upon due consideration is is hereby
ORDERED that on or before June 27, 2022, respondent shall file a status report attaching thereto any relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy-related penalty under section 6662(a).