Opinion
7375-22
05-23-2023
HENRY J. LANGER & PATRICIA K. LANGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Ronald L. Buch Judge
On May 18, 2023, the Commissioner filed a Motion to Dismiss for Lack of Prosecution as to Patricia K. Langer, deceased, and a Stipulation of Settlement between Commissioner and Petitioner, Henry J. Langer. The Commissioner advised the Court that Patricia K. Langer was deceased, that no representative or fiduciary is currently authorized to act on behalf of the estate of Patricia K. Langer, and that Mr. Langer does not object to the granting of the motion to dismiss as to Patricia K. Langer.
The Motion to Dismiss for Lack of Prosecution as to Patricia K. Langer, deceased, requests that the Court enter a decision against Ms. Langer in the same amounts and for the same years as is reflected in the Stipulation of Settlement between the Commissioner and Mr. Langer. After due consideration, it is
ORDERED that the caption of this case is amended to read "Henry J. Langer & Patricia K. Langer, Deceased, Petitioners v. Commissioner of Internal Revenue, Respondent." It is further
ORDERED that the Commissioner's Motion to Dismiss for Lack of Prosecution as to Patricia K. Langer, Deceased, filed May 18, 2023, is granted. It is further
ORDERED AND DECIDED that there are deficiencies in income tax due from the petitioners for the taxable years 2017 and 2018 in the amounts of $107,750.00 and $108,887.00, respectively; and that there are penalties due from petitioners for the taxable years 2017 and 2018, pursuant to I.R.C. section 6663, in the amounts of $80,812.50 and $81,665.25, respectively.