Opinion
22234-22S
04-24-2023
MOTI HAYATO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
By Notice of Deficiency dated August 31, 2022, respondent determined a deficiency in petitioner's Federal income tax for the taxable year 2020. On October 18, 2022, petitioner timely filed a Petition for redetermination. On December 6, 2022, respondent filed an Answer.
On April 21, 2023, counsel for petitioner electronically filed a document, designating it as a "Statement letter requesting case closure by Petitioner." Therein, counsel states that petitioner "has instructed [her] to close his case."
In a deficiency case where this Court has jurisdiction, as here, the Court is generally required to enter a decision specifying the amount of the deficiency, if any, for the taxable year at issue. See I.R.C. § 7459(d); Estate of Ming v. Commissioner, 62 T.C. 519 (1974). Thus, the Court is unable to close this case without entering a decision. Accordingly, the Court will direct the parties as set forth below.
In consideration of the foregoing, it is
ORDERED that the above-referenced "Statement" is recharacterized as petitioner's Status Report. It is further
ORDERED that, on or before May 24, 2023, the parties shall confer regarding the status of this case. It is further
ORDERED that, on or before June 8, 2023, the parties shall file either (1) a proposed stipulated decision for the Court's consideration or (2) a joint report regarding the then-present status of this case.