Opinion
4504-17
06-22-2023
PENNY L. ADKINS, TRANSFEREE, CHERYL COREDEIRO, TEMPORARY GUARDIAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Emin Toro, Judge
On June 13, 2023, respondent filed a Motion to Dismiss for Lack of Prosecution (Doc. 64). Respondent requests that the Court "find in its order that there is due from petitioner a total liability in the amount of $666,782.30, plus interest as provided by law from November 28, 2016, to the date such liability is paid, due from petitioner as transferee of assets of JSB Montana, Inc., f.k.a. Continental Television Network, Inc., transferor, for unpaid income tax of the transferor for the taxable year ended November 30, 2001, as set forth in the statutory notice of liability dated November 28, 2016, upon which notice the above-entitled case is based." Upon due consideration, and for cause more fully appearing in respondent's Motion to Dismiss for Lack of Prosecution, it is hereby
ORDERED that respondent's Motion to Dismiss for Lack of Prosecution filed June 13, 2023, is granted and this case is dismissed for lack of proper prosecution by petitioner. It is further
ORDERED AND DECIDED that there is a liability in the amount of $666,782.30, plus interest as provided by law from November 28, 2016, to the date such liability is paid, due from petitioner as transferee of assets of JSB Montana, Inc., f.k.a. Continental Television Network, Inc., transferor, for unpaid income tax of the transferor for the taxable year ended November 30, 2001. It is further
ORDERED that the Clerk of the Court shall, in addition to the regular service upon the parties, serve a copy of this Order on Cheryl Cordeiro, Temporary Guardian, at P.O. Box 1830, Great Falls, Montana, 59403.