Opinion
451-22S
04-14-2023
SUSAN C. AVERY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi, Special Trial Judge.
This case is currently calendared for trial at the Court's Winston-Salem trial session, which is scheduled to begin May 30, 2023. On March 13, 2023, the Court served an Order on the parties instructing respondent that, if the parties do not submit a proposed decision document which states there is not any section 6662(a) penalty due from petitioners for the year(s) in issue before April 14, 2023, then on or before April 14, 2023, respondent shall file a status report attaching thereto any relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy-related penalty under section 6662(a). On April 13, 2023, respondent filed a Status Report with the Court indicating that the case is with Office of Appeals.
Upon due consideration, it is hereby
ORDERED that if the parties do not submit a proposed decision document which states there is not any section 6662(a) penalty due from petitioners for the year(s) in issue before May 15, 2023, then on or before May 15, 2023, respondent shall file a status report attaching thereto any relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy-related penalty under section 6662(a).