Opinion
9847-22S
01-27-2023
TOMMY K. MCFATHER & RENEE H. MCFATHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Eunkyong Choi, Special Trial Judge.
This case is calendared for trial at the session of the Court to be conducted in person commencing on February 21, 2023, in Dallas, Texas. On January23, 2023, respondent filed a Motion to Dismiss for Failure to Properly Prosecute, indicating therein that petitioners, through petitioners' counsel, have not responded to respondent's reasonable requests for substantiation, have not provided the amended 2019 income tax return they allege has been prepared to correct the errors on their 2019 income tax return as filed, and have not provided a statement of reasonable cause regarding the proposed substantial understatement penalty. .
Upon due consideration, it is hereby
ORDERED that, on or before February 17, 2023, petitioners shall show cause in writing why respondent's Motion to Dismiss for Failure to Properly Prosecute filed January 23, 2023, should not be granted and a decision entered against petitioners for the amounts and year set forth in respondent's Motion.
Petitioners are advised that the failure to respond to this Order may result in the dismissal of this case and Entry of Decision as requested in respondent's Motion.