Opinion
15759-23
09-18-2024
WAYNE A. WORTHINGTON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Tamara W. Ashford, Judge.
This case is currently calendared for trial at the Session of the Court commencing on November 18, 2024, in Philadelphia, Pennsylvania. On September 17, 2024, respondent filed a Motion to Compel Production of Documents. Therein, respondent requests that petitioner produce all documents that are responsive to respondent's Request for Production of Documents served on petitioner on August 14, 2024. Upon due consideration, it is hereby
ORDERED that respondent's Motion to Compel Production of Documents, filed September 17, 2024, is granted in that on or before October 2, 2024, petitioner shall produce to counsel for respondent at the Internal Revenue Service Office of Chief Counsel, 600 Arch Street, 3rd Floor, Suite 03-H18-34, Philadelphia, Pennsylvania 19106, for inspection and copying all documents that are responsive to respondent's Request for Production of Documents served on petitioner on August 14, 2024. It is further
ORDERED that in the event petitioner does not fully comply with the provisions of this Order, the Court may impose sanctions under Tax Court Rule 104, which may include precluding petitioner from introducing into evidence at trial any matters which pertain to the category, event, transaction or circumstance to which the requested production of documents refer. Alternatively, the Court may dismiss this case and enter a decision against petitioner.