Opinion
13680-22
04-10-2024
JACK DONALD SUPINGER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge
This is before the Court on a Notice of Deficiency issued to petitioner for tax year 2018. This case was tried and submitted to the undersigned on July 19, 2023, at the remote Special Trial Session of the Court. In addition, there are several pending motions before the Court, including (1) petitioner's Motion for Entry of Decision, filed July 18, 2023, (2) respondent's oral Motion to Impose Sanctions, filed July 19, 2023, and (3) respondent's oral Motion to Deem the Affirmative Allegations in the First Amendment to Answer Admitted Pursuant to Rule 37(c).
Petitioner has filed three petitions with the Court for tax years 2017 (docket no. 10957-20), 2018 (docket number 13680-22), and 2019 (docket number 4810-23). In docket no. 10957-20 petitioner was held liable for a $5,000 penalty pursuant to I.R.C. section 6673(a) for maintaining frivolous or groundless positions. On March 13, 2023, petitioner filed a petition at docket number 4810-23, and on April 2, 2024, petitioner filed a Motion to Dismiss in docket number 4810-23. In that Motion to Dismiss, he states in part that he wishes to have his petition withdrawn and that he will "cease any further frivolous arguments" and on April 5, 2024, an Order and Decision was entered in that case. Upon due consideration, it is
ORDERED that, in light of petitioner's Motion to Dismiss in docket number 4810-23, petitioner shall, on or before May 10, 2024, file with the Court a status report or any motions he deems appropriate at that time, regarding his views with respect to the instant case.