Opinion
15855-23L
08-12-2024
PATRICK MCGOWAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Jennifer E. Siegel Special Trial Judge
On July 17, 2024, respondent filed a Motion for Summary Judgment and petitioner was directed to respond. On August 7, 2024, petitioner filed a Motion for Extension of Time. Acknowledging that petitioner is pro se though no stranger to this Court, we will grant the motion in that the time for petitioner to file a proper response to respondent's motion will be extended.
We once again direct petitioner to the Court's website where he can find the Tax Court Rules of Practice and Procedure, as well as Q&As that the Court has prepared on various topics, such as how to respond to a motion for summary judgment. We also direct petitioner's attention to I.R.C. section 6673(a) (allowing the Court to impose a penalty if it appears to the Court that a taxpayer's position in a proceeding before it is frivolous or groundless).
Upon due consideration, it is
ORDERED that petitioner's motion is granted in that the time within which petitioner shall file a proper response to respondent's Motion for Summary Judgment is extended to September 3, 2024. Absent compelling circumstances, further extensions are unlikely to be granted.