Opinion
13803-22S
11-02-2023
LAURENCE PUCKETT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Peter J. Panuthos Special Trial Judge.
By notice filed May 24, 2023, this case was set for trial on the Court's San Diego, California Trial Session commencing October 23, 2023. On October 2, 2023, respondent filed with the Court a Motion to Dismiss for Lack of Prosecution. Respondent asserted that petitioner failed to communicate as required by Tax Court rules.
On October 5, 2023, the Court issued an order advising petitioner that if there is an objection to respondent's motion, the objection should be filed on or before October 17, 2023. Petitioner did not respond to the Court's order dated October 5, 2023. When this case was called from the calendar at the Court's San Diego, California Trial Session on October 23, 2023, there was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard on the motion. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that respondent's Motion to Dismiss for Lack of Prosecution, filed October 2, 2023, is granted, and this case is hereby dismissed for lack of prosecution. It is further
ORDERED AND DECIDED that there are deficiencies in income tax, additions to tax, and penalties due from petitioner for the following taxable years:
Year
Deficiency
I.R.C. § 6662(a) Penalty
I.R.C. § 6651(a)(1) Addition to Tax
I.R.C. § 6651(a)(2) Addition to Tax
I.R.C. § 6654 Addition to Tax
2018
$10,432.00
$2,086.40
-
-
-
2019
$15,745.00
$3,149.00
-
-
-
2020
$15,890.00
-
$2,363.40
$367.64
$155.49