Opinion
8920-23S
05-21-2024
MICHAEL PIVARNIK & TRACY PIVARNIK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
By Order served March 21, 2024, this case was stricken for trial from the Court's April 2, 2024, Columbus, Ohio, trial session, jurisdiction was retained by the undersigned, and the parties were directed to submit to the Court stipulated decision documents.
On May 20, 2024, respondent filed a Motion for Entry of Decision (motion), requesting that the Court enter a decision in this case pursuant to the agreement of the parties and in accordance with the proposed decision document attached as Exhibit A, which reflects that there is not any deficiency in income tax due from petitioners for the taxable year 2020 and that there is not any accuracy-related penalty due from petitioners under the provisions of I.R.C. § 6662(b)(2); 6662(d) for the taxable year 2020. Petitioners' views on the granting of this motion are unknown. Upon due consideration, it is
ORDERED that, on or before June 4, 2024, petitioners shall file a response to respondent's Motion for Entry of Decision and indicate whether petitioner objects to the motion. Failure to comply with this Order may result in the granting of respondent's motion for entry of decision.