Opinion
10565-21S
04-18-2022
RICHARD NSIAH-YEBOAH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Eunkyong Choi Special Trial Judge
This case is currently calendared for trial at the Court's New York City, New York remote trial session, which is scheduled to begin June 13, 2022. In the Notice of Deficiency contained in petitioner's petition filed March 18, 2021, respondent asserted a penalty under section 6662(a).
On April 4, 2022, the Court filed an Order that if respondent wishes to continue to assert the accuracy-related penalty under section 6662(a) in this case, he shall file a status report and attach thereto a Case History Transcript and any other relevant documents to demonstrate compliance with section 6751(b)(1). Alternatively, if respondent concludes that he did not comply with the requirement under section 6751(b)(1) with respect to the accuracy-related penalty under section 6662(a), he should consider conceding that penalty and notify the Court by filing a status report on or before May 13, 2022.
On April 7, 2022, the parties filed a proposed Stipulated Decision in which respondent continued to assert the penalty. Since the parties filed a Proposed Stipulated Decision, the Court will direct respondent to file a response to our order served April 4, 2022. After due consideration, it is hereby
ORDERED that on or before May 13, 2022, respondent shall respond to the Court's Order served April 4, 2022. It is further
ORDERED that on or before May 13, 2022, respondent shall show cause in writing as to why they did not respond to the Court's April 4, 2022, Order before filing the Proposed Stipulated Decision.