Opinion
17515-19S
03-02-2023
CARLA DE LA GARZA, ESTATE OF JAVIER DE LA GARZA, DECEASED, CARLA DE LA GARZA, INDEPENDENT EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
By Order served February 7, 2023, the Court directed if the parties do not submit a proposed decision document which states there is not any section 6662(a) penalty due from petitioner for the year[s] in issue before March 21, 2023, then on or before March 21, 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 February 28, 2023, respondent filed a Status Report requesting additional time to provide the Court with evidence that the supervisory approval was obtained no later than the issuance to petitioners of the initial formal communication of proposed adjustments that includes penalties and provides the taxpayer the right to protest those proposed adjustments, such as a 30-day letter or Letter 525. Upon due consideration, it is
ORDERED that the time within which 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) is extended to March 27, 2023.