Opinion
19991-22
02-07-2024
PAUL ALFONSE SANTA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Tamara W. Ashford, Judge
This case is currently calendared for trial at the remote Session of the Court commencing on February 26, 2024. On February 5, 2024, respondent's counsel filed a Motion to Dismiss for Lack of Prosecution. Therein, respondent's counsel states that on or about November 10, 2022, petitioner's case was referred to the Internal Revenue Service Independent Office of Appeals (Appeals), and Appeals attempted to contact petitioner numerous times (including by letter dated January 12, 2023); however, petitioner was unresponsive. Respondent's counsel also states that since March 2023, she has attempted to contact petitioner numerous times and has been unsuccessful each time. Finally, in her motion, respondent's counsel outlines why the I.R.C. § 6662(a) penalty asserted against petitioner in this case is not subject to the requirements of I.R.C. § 6751(b)(1). It would be helpful for the Court to hear from petitioner regarding the motion and the status of this case. Upon due consideration, it is hereby
ORDERED that petitioner shall contact the chambers of the undersigned Judge at (202) 521-0822 as soon as possible for the purpose of scheduling a conference call to discuss the Motion to Dismiss for Lack of Prosecution, filed February 5, 2024, and the status of this case. It is further
ORDERED that petitioner shall show cause in writing, on or before February 20, 2024, why this case should not be dismissed for lack of prosecution.