Opinion
1335-21S
01-21-2022
Alan O'Kain & Victoria O'Kain Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Elizabeth Crewson Paris Judge
On October 13, 2021, the Court ordered respondent to file a report with the Court as to the documentation supporting the 6662 penalty in compliance with section 6751. On November 30, 2021, respondent filed a Status Report stating the Administrative record was not currently available. On January 14, 2022 Respondent filed a pretrial memorandum reflecting a penalty under 6662. After due consideration, it is
ORDERED that, on or before January 28, 2022, respondent shall file a status report updating the Court as to and including the supporting documentation in regard to the 6662 penalty in compliance with 6751 as referred to in respondent's Pretrial Memorandum.