Catlett v. Comm’r, No. 13058-14, T.C. Memo 2021-102 | August 16, 2021 | Lauber | Dkt. No. 13058-14
Short Summary: The taxpayer was convicted in 2011 on Federal criminal charges, including tax crimes and conspiracy to defraud the United States. In March 2011 he was sentenced to 210 months in prison. After he was remanded to custody, the IRS completed a civil examination of his 2006-2010 tax years. The IRS subsequently assessed substantial deficiencies, along with additions to tax and penalties. The taxpayer timely petitioned the Tax Court in June 2014. However, because of his incarceration, the case was repeatedly continued. The taxpayer died in January 2020, and the IRS filed a motion to dismiss the case based on lack of prosecution.
Key Issue: The key issue is the standard for dismissal when a taxpayer fails to prosecute their case. Various burdens come into play that the IRS must still meet despite the failure of the taxpayer to prosecute his case.
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