Opinion
21146-15
07-14-2022
TBL LICENSING LLC F.K.A. THE TIMBERLAND COMPANY, AND SUBSIDIARIES (A CONSOLIDATED GROUP), Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
James S. Halpern Judge.
Pursuant to the determination of this Court as set forth in its Supplemental Memorandum Opinion (T.C. Memo. 2022-71) filed July 12, 2022, it is
ORDERED that petitioner's motion for leave to file second amendment to petition filed March 25, 2022, is denied. It is further
ORDERED that so much of respondent's motion to vacate or revise pursuant to Rule 162 of the Tax Court Rules of Practice and Procedure, filed on March 4, 2022, that the Court held in abeyance, is granted. It is further
ORDERED AND DECIDED that there is a deficiency in income tax due from petitioner for the taxable year ended September 23, 2011, in the amount of $504,691,690.00.