Opinion
6657-21S
04-27-2022
SAMUEL DAVID GIBNEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
This case for the redetermination of deficiencies is before the Court on respondent's motion to dismiss for lack of prosecution, filed April 1, 2022, and heard on April 25, 2022, when the case was called from the calendar for trial during the Los Angeles, California, 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, for the reasons set forth in respondent's motion, and for cause set forth more fully in the transcript of the above-referenced proceedings, 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 2017, there is a $5, 686 deficiency in petitioner's Federal income tax, and petitioner is liable for a $1, 137.20 I.R.C. section 6662(a) penalty; and for 2018, there is a $5, 749 deficiency in petitioner's Federal income tax, and petitioner is liable for a $1, 149.80 I.R.C. section 6662(a) penalty.