Opinion
10584-23
04-02-2024
MICHAEL G. BROWN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Tamara W. Ashford, Judge
This case is currently calendared for trial at the Session of the Court commencing on April 22, 2024, in Las Vegas, Nevada. On April 1, 2024, respondent's counsel filed a Motion to Dismiss for Lack of Prosecution, requesting that the Court enter a decision reflecting that there is a deficiency in income tax due from petitioner for the 2019 taxable year in the amount of $33,455.00 and that there is a penalty due from petitioner under I.R.C. § 6662(a) for the 2019 taxable year in the amount of $3,345.50 (which amounts are less than the amounts asserted in the notice of deficiency issued to petitioner with respect to the 2019 taxable year). In her motion, respondent's counsel states that on March 26, 2024, she emailed petitioner's counsel to ascertain his views regarding the granting of the motion and in response petitioner's counsel stated that he would provide documents relating to petitioner's claimed expenses to her on March 29, 2024. Respondent's counsel further states that as of the date of the filing of her motion, she has not heard back from or received any correspondence or documents from petitioner's counsel or petitioner; thus, it is assumed that petitioner objects to the granting of the motion. It would be helpful for the Court to hear from petitioner regarding respondent's counsel's motion and the status of the case. Upon due consideration, it is hereby
ORDERED that petitioner's counsel shall contact the chambers of the undersigned Judge at (202) 521-0822 as soon as possible for the purpose of scheduling a conference call to discuss the Motion to Dismiss for Lack of Prosecution, filed April 1, 2024, and the status of this case. It is further
ORDERED that petitioner's counsel (on behalf of petitioner) shall show cause in writing, on or before April 12, 2024, why this case should not be dismissed for lack of prosecution.