Opinion
15455-22S
04-03-2023
DAVID G. WONG & BARBARA E. WONG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge
In the Notice of Deficiency contained in petitioner's petition filed June 17, 2022, with the Court, it is noted that respondent is assessing penalties under section 6662(a) upon petitioners. On February 21, 2023, 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 March 15, 2023, then on or before March 15, 2023, 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).
To date, respondent has not complied with the Court's Order served February 21, 2023, 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 February 21, 2023, and in an effort for expediency, if he wishes to assert a section 6662(a) penalty upon petitioners then on or before April 18, 2023, 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).