Opinion
26136-21S
04-30-2024
JOSEPH E. COLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Zachary S. Fried Special Trial Judge.
This case for the redetermination of a deficiency is before the Court on respondent's Motion to Dismiss for Lack of Prosecution, filed April 8, 2024, and heard on April 29, 2024, when the case was called from the calendar for trial during the Philadelphia, Pennsylvania trial session of the Court. Counsel for respondent appeared and argued in support of the motion. There was no appearance by or on behalf of petitioner.
Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceeding, it is
ORDERED that respondent's motion is granted, and this case is dismissed upon the stated ground. It is further
ORDERED and DECIDED that for 2018, there is an $11,966 deficiency in petitioner's federal income tax, and petitioner is not liable for an I.R.C. section 6662(a) penalty.