Opinion
18174-21L
03-09-2023
PHILIP J. CARR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
James S. Halpern Judge
This case is calendared for trial at the Court's March 20, 2023, Seattle, Washington, trial session.
On January 18, 2023, respondent filed a Motion for Summary Judgment, along with a Declaration in support. Petitioner was ordered to respond on or before February 21, 2023, but failed to do so. Substantially for the reasons set forth in respondent's Motion for Summary Judgment, along with the Declaration in support, it is
ORDERED that this case is stricken for trial from the Court's March 20, 2023, Seattle, Washington, trial session. It is further
ORDERED that respondent's Motion for Summary Judgment, filed on January 18, 2023, is granted. It is further
ORDERED AND DECIDED that respondent may proceed with the collection action for the taxable years 2014 and 2016, as determined in the Decision Letter on Equivalent Hearing Under Internal Revenue Code Sections 6320 and/or 6330, dated April 13, 2021, upon which this case is based.