Umoren v. Comm'r of Internal Revenue

Full title: ISANG E. UMOREN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jul 31, 2023

No. 10226-21L (U.S.T.C. Jul. 31, 2023)

Opinion

10226-21L

07-31-2023

ISANG E. UMOREN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Emin Toro, Judge

ORDER

Emin Toro, Judge

The Court held trial in this case on September 15, 2022, and issued its Oral Findings of Fact and Opinion on September 16, 2022. The Court entered its Decision in this case on October 21, 2022. The Decision stated:

Pursuant to the Court's Oral Findings of Fact and Opinion, rendered on September 16, 2022, it is hereby

ORDERED AND DECIDED that the determinations set forth in the Notices of Determination Concerning Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code both dated February 23, 2021, upon which this case is based, are sustained. It is further

ORDERED AND DECIDED that petitioner shall pay to the United States a penalty under section 6673(a)(1) in the amount of $2,000.

That Decision is now final. See I.R.C. § 7481, 7482, Rule 190.

On July 26, 2023, petitioner filed four documents titled: (1) Motion for Order to Show Cause Why Judgment Should Not Be Entered on the Basis of a Previously Decided Case, (2) Declaration in Support of Motion, (3) Brief in Support of Motion, and (4) a second Brief in Support of Motion (Docs. 99-102).

Although the title of the Motion is clear enough, the contents of the Motion and the accompanying papers are virtually unintelligible. It is not clear to the Court who should be ordered to show cause or what judgment should be entered on the basis of a previously decided case. Notwithstanding their titles, the additional filings appear to be attachments of various documents, such as transcripts of accounts and correspondence from the IRS. They too shed no light on what petitioner is seeking.

Given that the case has been closed for more than nine months and the Decision became final more than six months ago, and given it is not clear what relief petitioner seeks from the Court or that he is entitled to any relief that the Court is authorized to grant, the Court will deny the Motion.

In view of the foregoing, it is hereby

ORDERED that petitioner's Motion for Order to Show Cause Why Judgment Should Not Be Entered on the Basis of a Previously Decided Case (Doc. 99) filed July 26, 2023, is denied.

The case remains closed.