Opinion
5371-21
09-20-2023
NICOLE MARIE SAUL, PETITIONER AND CHRISTOPHER WEBB, INTERVENOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Courtney D. Jones Judge
On August 7, 2023, respondent filed a Motion for Entry of Decision. In the motion, respondent advised that the parties reached a basis for settlement prior to the date the Court set for trial of this case. Respondent's counsel received a signed copy of the proposed decision from petitioner's counsel on February 15, 2023. Respondent represents in his motion that intervenor Christopher Webb has not returned a signed copy of the proposed decision to respondent's counsel, despite having told respondent's counsel on April 23, 2023, that he would sign the proposed decision document.
By Order served August 9, 2023, the Court directed Mr. Webb to file an objection or response to the motion by August 30, 2023. Mr. Webb was warned that failure to respond to the Court's Order would likely result in the granting of respondent's motion and entry of decision as set forth at Exhibit A therein. To this date, the Court has not received a response to its Order, objection to respondent's Motion for Entry of Decision, returned mail, or any other correspondence from Mr. Webb. Upon due consideration, it is
ORDERED that respondent's Motion for Entry of Decision, filed August 7, 2023, is granted. It is further
ORDERED and DECIDED: There is a deficiency in income tax and a penalty due from petitioner Nicole Marie Saul before application of I.R.C. § 6015(c) as follows:
Year
Deficiency
2018
$15,436.00
$3,087.00