Opinion
12195-20
08-11-2022
RONALD STUDLE & SUSAN STUDLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge
On October 13, 2020, petitioners filed a Petition with the Court in which petitioners seek redetermination of deficiencies and penalties asserted by respondent in his Notice of Deficiency dated July 15, 2020, issued with respect to petitioners' 2015 and 2016 taxable years.
On May 31, 2022, the Court issued an order to show cause directing the parties to each show cause, in writing, on or before July 11, 2022, why the Court should not dismiss for lack of jurisdiction the portion of this case related to petitioners' 2016 taxable year on the ground that respondent has not asserted a deficiency for that tax year. On July 8, 2022, respondent filed a response to the Court's order to show cause issued May 31, 2022. Petitioners did not file any such response.
On June 6, 2022, the case was called for a remote trial at the session of the Court for cases in which Salt Lake City, Utah, was the place of trial. Counsel for respondent appeared and was heard. There was no appearance by or on behalf of petitioners. On the same day, the Court directed the parties to file on or before August 5, 2022, a proposed stipulated decision and the undersigned retained jurisdiction.
On August 5, 2022, the parties file a settlement stipulation and a proposed stipulated decision.
Accordingly, it is
ORDERED that the Court's order to show cause issued May 31, 2022, is hereby discharged.