Opinion
12257-21
11-21-2023
DAVID L. SEGEL, DECEASED, AND PATRICIA A. SEGEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
For the reasons set forth in respondent's motion to dismiss for lack of prosecution, filed September 28, 2023, and because there has been no response to the Order to Show Cause, served October 5, 2023, it is
ORDERED that the above-referenced Order to Show Cause is made absolute. It is further
ORDERED that respondent's motion to dismiss for lack of prosecution is granted, and so much of this case as relates to David L. Segel, Deceased, is dismissed upon the stated ground. It is further
ORDERED that in addition to regular service on the parties, the Clerk of the Court also serve a copy of this Order on Elissa Segel at the address shown for her in paragraph 3(a) of respondent's motion to dismiss for lack of prosecution. Taking into account the foregoing, and pursuant to the stipulation of settlement between respondent and petitioner Patricia A. Segel, it is further
ORDERED and DECIDED that there is a is a $2,500 deficiency in petitioners' 2018 federal income tax, and that after the application of § 6015(b), Patricia A. Segel's liability for that deficiency is limited to $850.