Opinion
11036-23S
06-10-2024
GREGORY P. BRENTS & PAULA A. BRENTS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Jennifer E. Siegel Special Trial Judge
This case was calendared at the trial session of the Court scheduled to commence in San Diego, California on June 3, 2024. On May 13, 2024, respondent filed a Motion to Dismiss for Lack of Prosecution. In the Court's May 16, 2024, Order setting the motion for hearing, we advised petitioners that failure to attend the hearing could result in the entry of decision as requested in respondent's motion. Despite this warning, there was no appearance by or on behalf of petitioners. Counsel for respondent appeared and was heard.
For cause more fully appearing in the transcript of the hearing, and giving due regard to the representations contained in respondent's motion, as well as the record of this case, it is
ORDERED that respondent's Motion to Dismiss for Lack of Prosecution is granted, and this case is dismissed for lack of prosecution. It is further
ORDERED and DECIDED that there are deficiencies in federal income tax due from petitioners for the taxable years 2020 and 2021 in the amounts of $13,190 and $19,789, respectively, as well as penalties due from petitioners for those years of $2,983 and $3,957.80 under the provisions of I.R.C. § 6662(a).