Opinion
25724-21
12-08-2021
Ronald Nathan Murch, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
MAURICE B. FOLEY CHIEF JUDGE
On October 19, 2021, the Court filed petitioner's letter dated October 14, 2021. Therein, petitioner requests that this case be dismissed on the ground that since filing the petition he has received an IRS Notice CP2005 indicating that the dispute over his Federal income tax liability for the 2018 taxable year has been resolved. A copy of the notice is attached to petitioner's letter.
In a deficiency case where this Court has jurisdiction, as here, the Court is generally required to enter a decision specifying the amount of the deficiency, if any, for the taxable year at issue. See I.R.C. sec. 7459(d); Estate of Ming v. Commissioner, 62 T.C. 519 (1974). We therefore lack authority to dismiss this case as petitioner requests. Accordingly, we will recharacterize petitioner's letter and direct the parties as set forth below.
The foregoing considered, it is
ORDERED that petitioner's above-referenced letter is recharacterized as petitioner's motion for entry of decision. It is further
ORDERED that, on or before January 10, 2022, respondent shall file a response to petitioner's motion for entry of decision, or the parties shall file a proposed stipulated decision.