Opinion
4063-22
10-20-2023
JOHN GERARD WATSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
ELIZABETH A. COPELAND JUDGE.
This case was called for trial on February 13, 2023, at the Trial Session of the Court in Philadelphia, Pennsylvania. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard. Respondent informed the Court that the parties had reached a basis of settlement, but petitioner needed additional time to sign the decision documents. Jurisdiction of this case was retained by this Division of the Court at that time.
On October 2, 2023, respondent filed with the Court a Motion for Entry of Decision. Respondent requests that, pursuant to Tax Court Rule 50, the Court enter a decision in this case pursuant to the agreement of the parties: that there is a deficiency in income tax due from petitioner for taxable year 2017 in the amount of $37,296.00; that there is an addition to tax due from petitioner for taxable year 2017 under the provisions of I.R.C. § 6651(a)(1) in the amount of $3,327.30; and that there is an addition to tax due from petitioner for taxable year 2017 under the provisions of I.R.C. § 6651(a)(2) in the amount of $3,697.00. Respondent informed the Court that petitioner has been unresponsive since February 13, 2023, despite multiple attempts.
Upon due consideration, and for cause, it is
ORDERED that, on or before November 20, 2023, petitioner shall show cause in writing as to why respondent's Motion for Entry of Decision should not be granted and why the Court should not enter a decision determining that he owes a deficiency in income tax due from petitioner for taxable year 2017 in the amount of $37,296.00; an addition to tax due for taxable year 2017 under the provisions of I.R.C. § 6651(a)(1) in the amount of $3,327.30; and an addition to tax due for taxable year 2017 under the provisions of I.R.C. § 6651(a)(2) in the amount of $3,697.00.
Petitioner shall also mail a copy of his written response to IRS Counsel Brian Salisbury at 600 Arch Street, Suite 03-L14-01, Philadelphia, PA 19106.