Opinion
22467-21S
09-13-2023
NANTAWOOT PETCHATAT & JILL NGUYEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge
This case is calendared for trial at the Court's September 25, 2023, Los Angeles, California trial session. On June 23, 2023, the Commissioner filed a Motion to Dismiss for Lack of Prosecution. The Court left a message for Nantawoot Petchatat and Jill Nguyen in an attempt to arrange a conference call with the parties; the Court's call was not returned. If Nantawoot Petchatat and Jill Nguyen would like to have a conference call with the Court, they may contact us at 202-521-0810. In the meantime, we will set the motion for hearing at the call of this case.
If the Court grants the Commissioner's Motion to Dismiss for Lack of Prosecution, then this case will be dismissed. A dismissal is treated as a determination that the adjustments contained in the Commissioner's notice of deficiency are correct. I.R.C. § 7459(d). But before taking action on the Commissioner's motion, we will provide Nantawoot Petchatat and Jill Nguyen an opportunity to appear at the scheduled trial session for this case. Accordingly, it is
ORDERED that the Commissioner's Motion to Dismiss for Lack of Prosecution filed June 23, 2023, is set for hearing at the call of the calendar at the trial session of the Court commencing September 25, 2023, at 10:00 a.m., Edward R. Roybal Center & Fed. Bldg., 255 E. Temple Street, Room 1167, Los Angeles, California 90012. Failure to appear may result in entry of decision for the Commissioner in the amount set forth in the Commissioner's motion.