King v. Comm'r of Internal Revenue

Full title: JACE KING, F.K.A. ALI TAVANA, Petitioner v. COMMISSIONER OF INTERNAL…

Court: United States Tax Court

Date published: Jul 13, 2023

No. 3800-20 (U.S.T.C. Jul. 13, 2023)

Opinion

3800-20

07-13-2023

JACE KING, F.K.A. ALI TAVANA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Emin Toro Judge

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 appeared to be duplicates, except respondent attached a proposed stipulated decision to the second Computation. By Order served June 6, 2023, the Court recharacterized respondent's second Computation as a Supplement to Computation for Entry of Decision. By the same Order, petitioner was directed to file on or before June 20, 2023, a response to respondent's Computation for Entry of Decision as supplemented.

Petitioner failed to file a response to respondent's Computation for Entry of Decision as supplemented, and the Court entered and served its Order and Decision on June 27, 2023.

On July 4, 2023, 14 days after the deadline established by the June 6 Order and 7 days after we entered a Decision closing this case, petitioner electronically filed a Response to Respondent's Computation for Entry of Decision (Doc. 69). Petitioner did not ask for leave to file the late Response, nor did petitioner move to vacate our Decision. And it is not clear to the Court what changes petitioner seeks with respect to the computations respondent submitted. In view of the foregoing, petitioner's Response is improperly filed. The Court will strike petitioner's Response from the record in this case.

Upon due consideration, it is hereby

ORDERED that petitioner's Response to Respondent's Computation for Entry of Decision filed July 4, 2023 (Doc. 69), is stricken from the record in this case.