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On August 18, 2006, our standing pretrial order and the
notice setting case for trial, scheduling trial in this case for
January 22, 2007, were served on petitioner by certified mail at
the address she provided in her petition. That mailing was not
returned by the U.S. Postal Service (USPS). On August 25, 2006,
the Court issued an order to file a joint status report to both
parties. This order was served on petitioner on August 28, 2006,
by certified mail at the address she provided in her petition.
That mailing was not returned by the USPS. Pursuant to the
Court's order, respondent filed respondent's status report on
September 25, 2006, in which he indicated he had been
unsuccessful in contacting petitioner and was therefore filing a
separate status report. Petitioner did not submit a status
report.
This case was called from the calendar for the trial session
of the Court that commenced on January 22, 2007, at Philadelphia,
Pennsylvania. There was no appearance by or on behalf of
petitioner. Counsel for respondent appeared and filed a motion
to dismiss for lack of prosecution (motion to dismiss) and a
motion for leave to file amended answer (motion to amend), and
lodged an amended answer with the Court. In his proposed amended
answer, respondent conceded petitioner's liability for the
section 6651(a)(2) addition to tax and, because that concession
removed the limitation imposed by section 6651(c)(1), respondent
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Last modified: November 10, 2007