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Leblon v. Comm'r of Internal Revenue

United States Tax Court
Mar 7, 2023
No. 25682-22S (U.S.T.C. Mar. 7, 2023)

Opinion

25682-22S

03-07-2023

GUILAUME LEBLON & FREDERIQUE MORTIER D'AUMONT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

Petitioners filed the petition in this case on November 18, 2022, seeking review of a notice of deficiency, dated August 16, 2022, issued to petitioners for tax year 2019. On January 30, 2023, petitioners filed a Motion to Dismiss.

In a deficiency case where the Court has jurisdiction, Internal Revenue Code section 7459(d) generally requires the Court to enter a decision as to the amount of the deficiency, if any. Settles v. Commissioner, 138 T.C. 372, 374 (2012). Because this case is based on a notice of deficiency, the Court is required to enter a decision and, accordingly, the petition in this case may not be withdrawn with or without prejudice.

Upon due consideration, it is

ORDERED that petitioners' Motion to Dismiss is denied. It is further

ORDERED that, on or before March 28, 2023, the parties shall either (1) submit stipulated decision documents so this case may be concluded, or (2) file status reports (preferably a joint report) with the Court concerning the then-present status of this case.


Summaries of

Leblon v. Comm'r of Internal Revenue

United States Tax Court
Mar 7, 2023
No. 25682-22S (U.S.T.C. Mar. 7, 2023)
Case details for

Leblon v. Comm'r of Internal Revenue

Case Details

Full title:GUILAUME LEBLON & FREDERIQUE MORTIER D'AUMONT, Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Mar 7, 2023

Citations

No. 25682-22S (U.S.T.C. Mar. 7, 2023)