Opinion
37584-21
06-12-2023
STEPHANIE S. DITTMER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER OF DISMISSAL AND DECISION
Courtney D. Jones Judge
This case was called from the calendar at the San Francisco, California trial session of the Court on April 3, 2023. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard. On April 4, 2023, respondent filed a Motion to Dismiss for Lack of Prosecution (Doc. 12).
The Court then ordered petitioner to show cause, on or before May 12, 2023, why respondent's motion to dismiss should not be granted and a decision entered against her for the amount and year set forth in respondent's Motion to Dismiss for Lack of Prosecution (Doc. 14). To this date, the Court has not received a response to its Order to Show Cause, objection to respondent's Motion to Dismiss for Lack of Prosecution, returned mail, or any other correspondence from petitioner.
Giving due regard to the representations contained in respondent's motion to dismiss, and due to petitioner's failure to respond to the Court's Order to Show Cause, failure to appear for trial, and failure to otherwise prosecute this case, it is
ORDERED that the Court's April 12, 2023, Order to Show Cause is made absolute. It is further
ORDERED that respondent's April 4, 2023, 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 is a deficiency in Federal income tax and additions to tax due from petitioner as follows:
Year
Deficiency
I.R.C. § 6651(a)(1) Addition to Tax
I.R.C. § 6651(a)(2) Addition to Tax
2018
$61,325.00
$4,777.65
$3,078.93