Opinion
19874-22S
08-21-2023
ARTURO DANIEL MERINO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
This case is calendared for trial at the December 4, 2023, Phoenix, Arizona, Trial Session of the Court.
By Order served July 24, 2023, the Court directed that, if the parties do not submit a proposed decision document which states there is not any section 6662(a) penalty due from petitioner for the year[s] in issue before August 24, 2023, then on or before August 24, 2023, respondent shall file a status report attaching thereto a Case History Transcript and any other relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy-related penalty under section 6662(a).
On August 18, 2023, respondent filed a Status Report. Upon due consideration and for cause, it is
ORDERED that, on or before September 5, 2023, respondent shall file a copy of the Case History Transcript.