Opinion
6452-22SL
12-13-2023
QUOC TIEN HOANG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Jennifer E. Siegel Special Trial Judge
Petitioner filed a petition to commence this case in response to a Notice of Determination Concerning Collection Actions under IRS Sections 6320 or 6330 of the Internal Revenue Code dated February 23, 2022, concerning his 2014 tax year. By Notice Setting Case for Trial issued August 2, 2023, this case was calendared for trial at the Court's December 11, 2023, San Francisco, California, trial session.
On October 12, 2023, respondent filed a Motion for Summary Judgment. The Court directed petitioner to respond to the motion by November 13, 2023. No response was received from petitioner. The Court then calendared the motion for a hearing and directed petitioner to appear and show cause why the case should not be dismissed for lack of prosecution. No response to the Court's Order was received. Petitioner did not appear when the case was called, and he did not appear when the case was later recalled.
Upon due consideration of the record and for cause, it is ORDERED that respondent's Motion for Summary Judgment is denied as moot. It is further
ORDERED that the Court's order to show cause is made absolute, and this case is dismissed for lack of prosecution. It is further
ORDERED and DECIDED that respondent may proceed with the collection action as determined in the above-referenced notice of determination.