Opinion
9591-24
07-12-2024
RALPH B. TORGERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 10, 2024, the Court received and filed the Petition to commence this case. Therein, petitioner disputes a notice of deficiency dated March 25, 2024, determining a deficiency in his federal income tax for the taxable year 2021.
Thereafter, on July 8, 2024, the Court received and filed a letter by petitioner dated July 1, 2024. Attached to the letter is an Internal Revenue Service (IRS) Notice CP2000 dated June 24, 2024, advising petitioner that, based on his previous response, the IRS has determined that he owes $0.00 for the taxable year 2021. In his letter, petitioner states that this "outcome is totally satisfactory to [him]."
The foregoing suggests that the parties in this case may have resolved their dispute over petitioner's federal income tax liability for the taxable year 2021. However, in a deficiency case, 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). Accordingly, we will direct the parties in this case to file either a proposed decision document reflecting their settlement agreement, if any, or a joint status report as set forth below.
Upon due consideration and for cause, it is
ORDERED that petitioner's above-referenced letter is recharacterized as petitioner's Status Report. It is further
ORDERED that, on or before August 30, 2024, the parties shall file with the Court either (1) a proposed stipulated decision or (2) a joint report regarding the then-present status of this case.