Opinion
3800-20
06-06-2023
JACE KING, F.K.A. ALI TAVANA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge.
This case was tried in Los Angeles, California, on January 17, 2023. The Court rendered its bench opinion on January 18, 2023, and served a transcript of it on the parties on February 23, 2023 (Doc. 64), providing in our Order that a "Decision will be entered under Rule 155" -- i.e., that the parties would comply with Rule 155 in order to compute the correct amount for the decision to be entered.
In response to our Order, on April 20, 2023, respondent filed Computation for Entry of Decision (Doc. 65). On April 21, 2023, respondent filed a second Computation for Entry of Decision (Doc. 66). The Computations for Entry of Decision appear to be duplicates except respondent attached a proposed stipulated decision to the second Computation. The Court will recharacterize respondent's second Computation as a Supplement to Computation for Entry of Decision.
The Court notes that respondent's Computation for Entry of Decision and Supplement to Computation for Entry of Decision were both electronically served on petitioner; however, as of the date of this Order, no computations have been received from or on behalf of petitioner.
Upon due consideration, it is hereby
ORDERED that respondent's Computation for Entry of Decision filed April 21, 2023, is recharacterized as respondent's Supplement to Computation for Entry of Decision. It is further
ORDERED that on or before June 20, 2023, petitioner shall file a response to respondent's Computation for Entry of Decision as supplemented. If he disagrees with respondent's Computation as supplemented, he shall specify in detail the basis for his disagreement and state what he believes the correct tax computation to be. If petitioner does not respond to this Order, the Court will enter a decision consistent with respondent's computation as supplemented.