Opinion
899-20
12-02-2021
ORDER
Albert G. Lauber, Judge
On November 22, 2021, respondent filed a Motion to Dismiss for Failure to Properly Prosecute. On November 29, 2021, this case was called from the calendar for the Court's San Francisco, California, remote trial session. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that petitioner shall file a response to respondent's Motion to Dismiss for Failure to Properly Prosecute on or before December 30, 2021. Petitioner is advised that if he fails to respond to this Order, the Court will likely grant respondent's Motion and enter a decision against him in the amount set forth in respondent's Motion: $6,995. Respondent has conceded the penalty under I.R.C. § 6662(a) in the amount of $1,399.