Opinion
34505-21
02-15-2023
GREGORY SAPP, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Elizabeth A. Copeland Judge.
This case was called from the calendar at the Court's February 13, 2023, Philadelphia, Pennsylvania Trial Session. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard. On January 4, 2023, respondent filed with the Court a Motion to Dismiss for Failure to Properly Prosecute. On January 11, 2023, the Court issued an Order requiring a response from petitioner on or before February 1, 2023, as to why this case should not be dismissed for failure to properly prosecute. There has been no response from petitioner to date.
Upon due consideration, and for cause, it is
ORDERED that respondent's Motion to Dismiss for Failure to Properly Prosecute, filed with the Court on January 4, 2023, is granted. It is further
ORDERED AND DECIDED that for the taxable year of 2019, there is a deficiency in income tax due from petitioner in the amount of $7,907; and
That there is a substantial tax understatement penalty of $1,147 due from petitioner for the taxable year 2019, under the provisions of I.R.C. § 6662(a).