Opinion
14290-23L
03-18-2024
SANFORD T. PULLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
L. Paige Marvel Judge.
Respondent filed a Motion for Summary Judgment (Motion) on February 15, 2024. On February 20, 2024, we ordered petitioner to file a response to respondent's Motion on or before March 8, 2024. To date, petitioner has not filed a response, despite being warned in our Order that a decision may be entered against him if he failed to respond. See Rule 121(d).
Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent's Motion is factually supported, and its factual assertions are not disputed by petitioner. The Motion's legal arguments are sound, and petitioner offers no contrary authorities or argument. Summary judgment is therefore warranted both on the merits and, under Rule 121(d), as a consequence of petitioner's failure to respond to the Motion. It is therefore
ORDERED that respondent's Motion for Summary Judgment, filed February 15, 2024, is granted. It is further
ORDERED AND DECIDED that the collection action as determined in the Notice of Determination Concerning Collection Actions under IRS Sections 6320 or 6330 of the Internal Revenue Code, dated August 7, 2023, upon which this case is based, is sustained in full.