Opinion
10144-18S
10-15-2021
David A. Liberino & Michelle C. Liberino-Poulsen Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Peter J. Panuthos Special Trial Judge
By Notice dated February 2, 2021, this case was calendared for trial on the Court's May 17, 2021, San Diego, California remote trial calendar. In a status report filed, May 13, 2021, respondent advised that the parties had reached a verbal basis of settlement.
When this case was called from the trial calendar on May 17, 2021, the Court directed that the parties shall, on or before June 17, 2021, submit settlement documents in this matter.
On June 17, 2021 respondent filed a status report advising that petitioners had not signed and returned the settlement documents and had become unresponsive to respondent's attempts at communication. Respondent requested an additional 30 days to submit settlement documents. On August 13, 2021, respondent filed a Motion For Entry of Decision.
The Court issued an Order on August 20, 2021, directing petitioners to file an objection, if any, to respondent's motion. There has been no response from petitioners. The Court will grant respondent's motion.
Premises considered, it is
ORDERED that respondent's Motion for Entry of Decision, filed August 13, 2021, is granted. It is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioners for the 2015 tax year in the amount of $7,800; and
That there is no penalty due from petitioners for the tax year 2015, under the provisions of I.R.C. section 6662(a).