Opinion
10346-20
05-07-2024
PRADEEP KHANNA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
This case for the redeterminations of deficiencies was called from the calendar for an oral status report on May 6, 2024, in New York, New York (report). The report focused on two pending motions: (1) petitioner's motion to restrain assessment, filed November 20, 2020; and (2) respondent's motion to dismiss for lack of jurisdiction, filed March 12, 2021. Respondent's motion is directed to certain I.R.C. section 6038 penalties challenged in the petition.
Counsel for the parties appeared and advised the Court that they have a reasonable expectation that this case, along with other matters relating to petitioner's federal tax liabilities, will soon be settled.
Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED that petitioner's motion is denied, without prejudice. It is further
ORDERED that respondent's motion is granted, and so much of this case as relates to the I.R.C. section 6038 penalties challenged in the petition is dismissed for lack of jurisdiction. It is further
ORDERED that if matters do not progress as reported, then either party's motion to reconsider or vacate this Order, or any portion of it, will be timely if made not later than 60 days from the date of service. See Rule 54(a), Tax Court Rules of Practice and Procedure.