Opinion
887-23
06-06-2023
FINANCIAL PLANNING CENTER, DEV X, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
On March 28, 2023, respondent filed a Motion to Close on Ground of Duplication. On June 5, 2023, petitioner filed an Objection to Motion to Close on Ground of Duplication.
By Order served May 15, 2023, the parties were directed to show cause in writing why this case should not be dismissed for lack of jurisdiction consistent with I.R.C. section 6226(b)(4). The parties failed to do so.
Premises considered, it is ORDERED that respondent's Motion to Close on Ground of Duplication is denied as moot. It is further
ORDERED that the Court's Order to Show Cause dated May 15, 2023, is hereby made absolute. It is further
ORDERED that this case is dismissed for lack of jurisdiction on the ground that a prior petition was filed in respect to Financial Planning Center's 2016 tax year.