Opinion
36062-21S
03-03-2023
CYNTHIA LITTLE, DECEASED, & RICKIE C. LITTLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Adam B. Landy Special Trial Judge
This case was scheduled for trial at the Court's October 11, 2022, Atlanta, Georgia, trial session.
On October 31, 2022, respondent filed a Motion to Dismiss for Lack of Prosecution as to Cynthia Little, Deceased. On November 21, 2022, the Court ordered the surviving spouse and petitioner Cynthia Little's heirs-at-law, Deandra Short and Dominique Little, to show cause, on or before December 28, 2022, why respondent's motion to dismiss should not be granted. Neither the surviving spouse nor heirs-at-law objected to respondent's motion. On January 9, 2023, the Court granted respondent's motion and dismissed Cynthia Little, Deceased as a petitioner for lack of prosecution. On February 27, 2023, the parties filed a stipulation of settled issues resolving all remaining issues in this case.
Upon due consideration of the stipulation of settled issues between respondent and petitioner Rickie C. Little, filed February 27, 2023, it is
ORDERED and DECIDED that, for taxable year 2019, there is a deficiency in income due from petitioners in the amount of $88.00, and there is no accuracy-related penalty, pursuant to I.R.C. § 6662(a), due from petitioners.