Savela v. Comm'r of Internal Revenue

Full title: JAYSON SAVELA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Feb 9, 2022

No. 12393-20 (U.S.T.C. Feb. 9, 2022)

Opinion

12393-20

02-09-2022

JAYSON SAVELA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Mary Ann Cohen, Judge

ORDER TO SHOW CAUSE

Mary Ann Cohen, Judge

This case was assigned to the undersigned judge on February 7, 2022. On October 19, 2020, petitioner filed a Petition for Review of Failure to Abate Interest Under Code Section 6404. By Order served October 23, 2020, petitioner was directed to pay the Court's filing fee or submit an Application for Waiver of Filing Fee on or before January 21, 2021. By separate Order also served on October 23, 2020, petitioner was further directed to file a Ratification of Petition on or before January 21, 2021, bearing an original signature in which petitioner states that he had read the petition filed on October 19, 2020, and ratify and affirm the filing of said document. As of the date of this Order, no response has been received by or on behalf of petitioner to the October 23, 2020, Orders.

On June 25, 2021, respondent filed a Motion for Summary Judgment together with a Declaration of Timothy M. Peel in Support of Motion for Summary Judgment. By Order served June 29, 2021, petitioner was directed to file a response on or before July 26, 2021. That order stated:

...petitioner should point out the specific facts in dispute if petitioner disagrees with the facts set forth in respondent's motion, and petitioner should state petitioner's position on the disputed legal issues if petitioner disagrees with respondent's argument as to the law.

ORDERED that, on or before July 26, 2021, petitioner shall file a response, if any, to the just-described Motion for Summary Judgment. Failure to comply with this Order may result in the granting of respondent's motion for summary judgment and a decision, if appropriate, may be entered against petitioner. See Rule 121(b), Tax

Court Rules of Practice and Procedure.

As of the date of this Order, no response has been received by or on behalf of petitioner to the June 29, 2021, Order.

Upon due consideration, it is hereby

ORDERED that on or before March 11, 2022, petitioner shall show cause, if any he has, why this case should not be dismissed by reason of petitioner's failure to comply with this Court's Orders and Rules. Such showing shall include a response to respondent's Motion for Summary Judgment containing the information identified in the Order served June 29, 2021, quoted above.