Opinion
26914-22S
06-11-2024
JACOB C. E. PULLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge
This case was called at the Court's February 5, 2024, San Francisco, California, trial session. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and advised that the parties had reached a basis for settlement, and the Court directed the parties to file settlement documents on or before April 5, 2024. On April 5, 2024, respondent filed a Motion for Extension of Time to File Decision Document, indicating more time was needed to file settlement documents.
On June 4, 2024, respondent filed a Motion for Entry of Decision (Motion), requesting that the Court enter a decision in this case in accordance with the decision document attached to the Motion as Exhibit A, which reflects that there is no deficiency in federal income tax due from, nor overpayment due to petitioner for taxable year 2020, and that there is no accuracy-related penalty under I.R.C. § 6662(a) due from petitioner for taxable year 2020. Respondent represents in his Motion that petitioner has been unresponsive to communication and that petitioner's views on the granting of the Motion are unknown. Upon due consideration, it is
ORDERED that respondent Motion for Extension of Time to File Decision Document, filed April 5, 2024, is denied as moot. It is further
ORDERED that, on or before July 8, 2024, petitioner shall file a response to respondent's Motion for Entry of Decision, filed June 4, 2024, stating 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.