Opinion
14140-20
03-25-2022
Bear Creek SK Holdings, LLC, Strategic Securities Holdings II, LLC, A Partner Other Than the Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley, Chief Judge
On October 20, 2020, a petition was filed at Docket No. 12400-20 based upon the same notice of final partnership administrative adjustment as forms the basis for this case. Subsequently, on December 11, 2020, petitioner filed the petition in this case.
Under section 6226(b)(2) and (4), if more that one partnership action case is commenced with respect to a partnership for the same taxable year, the first case commenced goes forward and subsequent cases are dismissed.
Premises considered, it is
ORDERED that, on or before April 13, 2022, the parties shall show cause why this case should not be dismissed for lack of jurisdiction on the ground a timely petition was previously filed with respect to the same Notice of Final Partnership Administrative Adjustment as forms the basis for this case.