Opinion
5511-18L
12-05-2022
SEASHORE BROADCASTING CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge
On August 5, 2022, the Court issued an Order granting in part and denying in part respondent's September 11, 2020 Motion for Summary Judgment. Subsequently, on August 22, 2022, the Court issued an opinion in Warner Enterprises, Inc. v. Commissioner, which addresses the same issue we addressed regarding respondent's duty to comply with section 6751(b) as part of the verification required by section 6330(c)(1) but reaches the opposite conclusion. See T.C. Memo 2022-85 at *6.
For cause, it is
ORDERED that the Court's Order dated August 5, 2022, is vacated.