Opinion
19132-21S
08-23-2022
MARY C. TITUS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
EUNKYONG CHOI SPECIAL TRIAL JUDGE
In the Notice of Deficiency contained in petitioner's petition filed May 28, 2021 with the Court, it is noted that respondent is assessing penalties under section 6662(a) upon petitioners. On August 8, 2022, the Court served an Order on the parties instructing respondent that, if the parties do not submit a proposed decision document which states there is not any section 6662(a) penalty due from petitioners for the year(s) in issue before September 30, 2022, then on or before September 30, 2022, respondent shall file a status report attaching thereto any relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy-related penalty under section 6662(a).
On August 19, 2022, the parties filed a Proposed Stipulated Decision with the Court in which respondent asserts that there are penalties due from petitioners for the taxable year 2018, under the provisions of I.R.C. §6662(a) in amount of $1,037.00. However, respondent has not complied with the Courts Order served August 8, 2022, providing the Court relevant documents demonstrating compliance with section 6751(b)(1) or notifying the Court whether respondent concedes the accuracy-related penalty under section 6662(a).
Upon due consideration of the foregoing, it is hereby
ORDERED that respondent is directed to comply with the Courts Order served August 8, 2022 and in an effort for expediency, if he wishes to assert a section 6662(a) penalty upon petitioners then on or before September 30, 2022, respondent shall file a status report attaching thereto any relevant documents to demonstrate compliance with section 6751(b)(1) or notifying the Court whether he concedes the accuracy related penalty under section 6662(a).