Opinion
9608-24S
08-07-2024
BRETT WAYNE SAVAGE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 11, 2024, petitioner electronically filed the Petition to commence this case. Therein, petitioner seeks redetermination of a deficiency in income tax for the taxable year 2021. However, on August 6, 2024, petitioner filed a Motion to Dismiss, accompanied by a declaration, requesting that the Court dismiss the case because petitioner intends to "pursue an administrative resolution with the IRS."
In a deficiency case, as here, we are generally required to enter a decision specifying the amount of the deficiency, if any, for the taxable year at issue. See I.R.C. § 7459(d); Estate of Ming v. Commissioner, 62 T.C. 519 (1974). Because we cannot simply dismiss petitioner's case without entering a decision, we will deny his Motion to Dismiss.
To the extent petitioner wishes to pursue a settlement with the Internal Revenue Service as to his 2021 tax liability, he may contact the attorney representing respondent (i.e., the IRS) in this matter. The contact information for that attorney is included in the Answer that respondent filed on July 26, 2024. For further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioner's above-referenced Motion is denied.