Opinion
24201-22L
05-08-2024
AMERICAN PROTECTION SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Patrick J. Urda, Judge.
On February 28, 2024, the Commissioner filed a motion for summary judgement. On March 4, 2024, the Court directed petitioner American Protection Services, Inc. to file a response to the motion by March 21, 2024. Petitioner did not file a response to the motion for summary judgment.
This case was called from the calendar on April 29, 2024, during the Jackson, Mississippi Trial Session of the Court. There was no appearance by petitioner nor anyone on its behalf. Counsel for the Commissioner appeared and made an oral motion to dismiss for failure to properly prosecute. This case was set to be recalled the next day.
This case was recalled from the calendar on April 30, 2024. Again, there was no appearance by petitioner or anyone acting on its behalf. Counsel for the Commissioner appeared and was heard. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the Commissioner's motion for summary judgement filed on February 28, 2024, is taken under advisement. It is further
ORDERED that the Commissioner's oral motion for failure to properly prosecute is taken under advisement. It is further
ORDERED that, on or before May 30, 2024, American Protection Services, Inc. shall show cause in writing as to why the Court should not grant the Commissioner's oral motion to dismiss failure to properly prosecute and enter a decision sustaining the notice of determination concerning collection actions under IRS sections 6320 or 6330 of the Internal Revenue Code dated October 17, 2022. It is further
ORDERED that jurisdiction of this case is retained by the undersigned.