Opinion
12853-20
10-18-2022
JON ERIK ROCHA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Lewis R. Carluzzo Chief Special Trial Judge
This case, recalled from the calendar for trial in Dallas, Texas, on October 12, 2022, is before the Court on respondent's motion to dismiss, filed September 16, 2022. Counsel for respondent appeared and was heard. There was no appearance by or on behalf of petitioner.
Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED that respondent's motion is granted, and this case is dismissed upon the ground relied upon in respondent's motion for each year referenced in the motion.
Petitioner's attention is invited to I.R.C. section 6673(a). If it appears to the Court that a taxpayer's position in a proceeding before the Court is frivolous or groundless, then the Court can impose a penalty (not to exceed $25,000) on that taxpayer. Petitioner is advised that it appears to the Court that the position he has taken in this case is frivolous or groundless. No penalty will be imposed at this time. However, future submissions advancing a frivolous or groundless position will result in the imposition of a penalty.