Opinion
6801-23S
05-19-2023
DOUGLAS C. SQUIERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 15, 2023, the Court received and filed a Letter by petitioner dated May 8, 2023. The Letter states in relevant part: "I request a dismissal of this case as the Internal Revenue Service has reversed their claim that additional tax for the year 2020 was owed by this Petitioner." Attached to the Letter is an apparent IRS Notice CP2005 dated April 17, 2023, indicating that the inquiry into petitioner's federal income tax for the taxable year 2020 has been closed with an amount due of $0.00.
In a deficiency case where the Court has jurisdiction, 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). We are therefore unable to grant the relief that petitioner seeks. However, in view of petitioner's request, and the fact that the dispute over the underlying tax liability in this case appears to have been resolved, we will take action as set forth below.
In consideration of the foregoing, it is
ORDERED that petitioner's above-referenced Letter is recharacterized as petitioner's Motion for Entry of Decision. It is further
ORDERED that, on or before June 20, 2023, either (1) respondent shall file a response to petitioner's Motion for Entry of Decision or (2) the parties shall file a proposed stipulated decision for the Court's consideration.