Opinion
24231-22S
12-14-2023
HEATHER L. MCINTYRE Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Jennifer E. Siegel Special Trial Judge
Petitioner filed a petition to commence this case in response to a Notice of Deficiency dated October 11, 2022. By Notice Setting Case for Trial issued August 2, 2023, this case was calendared for trial at the Court's December 11, 2023, San Francisco, California, trial session.
On November 14, 2023, respondent filed a Motion to Dismiss for Failure to Properly Prosecute. The Court directed petitioner to respond to the motion by December 1, 2023. No response was received from petitioner. The Court also calendared the motion for a hearing. There was no response from petitioner, and she did not appear when the case was called. Respondent appeared and was heard.
Upon due consideration of the record, respondent's motion, and for cause, it is
ORDERED that respondent's motion is granted, and this case is dismissed for failure to properly prosecute. It is further
ORDERED and DECIDED that there are deficiencies and accuracy-related penalties due from petitioner in the amounts shown below:
| Year | Deficiency | I.R.C. Section 6662 |
| 2018 | $10,728.00 | $2,145.60 |
| 2019 | $6,567.00 | $1,313.40 |