Opinion
1250-20
02-03-2022
Ana Margarita Fiengo, Petitioner and Pascual E. Fiengo, Sr., Intervenor Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
CHRISTIAN N. WEILER, JUDGE
On March 29, 2021, respondent filed a Motion to Dismiss for Failure to Properly Prosecute.
Following the oral findings of fact and opinion rendered in the above case before Judge Christian N. Weiler at Jacksonville, Florida (remote proceeding) on December 13, 2021, containing his oral findings of fact and opinion rendered at the conclusion of the trial pursuant to Rule 152(b), Tax Court Rules of Practice and Procedure, it is
ORDERED that respondent's Motion to Dismiss for Failure to Properly Prosecute filed on March 29, 2021, is hereby denied as moot. It is further
ORDERED AND DECIDED that respondent's final determination that petitioner is not entitled to relief from joint and several liability under I.R.C. section 6015 for the taxable years 2011-14, is sustained.