Opinion
13679-22
09-30-2024
BENSSON SAMUEL & MAGDALENA SAMUEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo, Chief Special Trial Judge
This case for the redetermination of a deficiency is before the Court on respondent's motion to dismiss for failure properly to prosecute, filed July 22, 2024, and heard in Detroit, Michigan, on September 26, 2024.
Counsel for respondent appeared and argued in support of the motion. Counsel for petitioner appeared and opposed it.
Although the Court certainly appreciates and encourages early trial preparation efforts as described in respondent's motion, the relief sought in the motion is simply too severe to justify at this stage of the proceedings. That being so, and for reasons set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED that respondent's motion is denied.