Opinion
23550-18
02-23-2023
JIN S. KIM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
On March 24, 2022, the parties filed a stipulation of settled issues in this case. Respondent's counsel prepared tax computations based on the parties' agreement and sent petitioner a proposed decision document reflecting those computations. Petitioner did not return an executed decision document. Respondent subsequently made a partial concession of the I.R.C. § 6651(f) addition to tax, agreeing to compute it at a rate of 15% rather than 75%. He then sent petitioner a revised decision document reflecting this additional concession.
Having received no executed decision document from petitioner, respondent's counsel called him on February 10, 2023, but was unable to reach him. On February 17, 2023, respondent filed a Motion for Entry of Decision, requesting that we enter the decision attached as Exhibit A to the Motion, which reflects respondent's additional concession as set forth above. Respondent has been unable to ascertain petitioner's position regarding the granting of this Motion.
In consideration of the foregoing, it is
ORDERED that petitioner shall file, on or before March 22, 2023, a response to respondent's Motion for Entry of Decision. If petitioner does not respond, the Court will enter a decision for the revised amounts stated in the Motion.