Opinion
1043-23S
02-13-2024
HOSAM AHMED & JOANNE AHMED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
On February 9, 2024, the Commissioner filed a Motion for Entry of Decision. This Motion asks the Court to enter a decision that there is a deficiency in income tax due from petitioners, but there is no penalty due from petitioners pursuant to section 6662 or 6676 for the taxable year at issue. The Commissioner further states that petitioners' views on his Motion are unknown.
Statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times.
Upon due consideration of the Commissioner's Motion, and for cause, it is
ORDERED that, on or before March 1, 2024, petitioners shall file an objection, if any, to the Commissioner's Motion for Entry of Decision. Failure to file a response or an objection may result in the granting of the Commissioner's Motion.