Opinion
13585-20
01-24-2024
BSR PROPERTIES, LLC, FCT AD, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge.
This case was continued from the Court's January 9, 2023, Atlanta, Georgia trial session and jurisdiction was retained by the undersigned.
Since then, the Commissioner has filed multiple status reports. The Court held conference calls with the parties in the summer of 2023. During those calls, petitioner BSR Properties, LLC, FCT AD, LLC, Tax Matters Partner's (BSR) representative, Pete Davis, informed the Court that he was in the process of hiring counsel to represent BSR in this proceeding. To date, no entry of appearance for petitioner has been filed. The Court attempted to schedule another conference call to obtain a status on this case but has not been able to reach Mr. Davis, or anyone from BSR.
We remind BSR that under Rule 123(b), Tax Court Rules of Practice and Procedure, a petitioner's failure to comply with any order of the Court, or for any other cause which the Court deems sufficient, the Court may dismiss a case at any time and enter a decision against the petitioner.
Upon due consideration, it is
ORDERED that no later than February 2, 2024, petitioner shall telephone the Chambers of the undersigned judge at (202)521-0800 for the purpose of scheduling a telephone conference.