Opinion
12654-20SL
03-31-2023
LIL ORBITS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL AND DECISION
Adam B. Landy, Special Trial Judge.
By Order dated November 13, 2020, the Court directed petitioner to file, on or before February 11, 2021, an Ownership Disclosure Statement pursuant to Rule 20(c). A copy of Form 6, Ownership Disclosure Statement, was attached to the copy of the Order served on petitioner. Petitioner failed to file an Ownership Disclosure Statement as directed.
Rule references are to the Tax Court Rules of Practice and Procedure, available on the Tax Court's website, www.ustaxcourt.gov.
The Court received a proposed stipulated decision from the parties on January 19, 2023. By Order dated January 25, 2023, the Court ordered petitioner to show cause in writing, on or before March 17, 2023, why the Court should not dismiss this case, pursuant to Rule 123, for petitioner's noncompliance with the Court's Order dated November 13, 2020. A copy of Form 6, Ownership Disclosure Statement, was again attached to the copy of the Order to Show Cause served on petitioner. Petitioner failed to respond to the Order to Show Cause.
After the March 17, 2023, deadline, the Court reached out to petitioner, by and through its representative, to encourage compliance with the Court's Orders. As of the date of service of this Order of Dismissal and Decision, petitioner failed to comply with the Court's Orders.
Upon due consideration and for cause, it is
ORDERED that the Court's Order to Show Cause, issued January 25, 2023, is hereby made absolute. It is further
ORDERED that this case is dismissed for lack of prosecution, pursuant to Rule 123, and this case is also dismissed for petitioner's failure to file Form 6. It is further
ORDERED AND DECIDED: That the determinations set forth in the Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code issued to petitioner on September 22, 2020, as supplemented by the Notice of Determination Concerning IRS Collections Actions under Internal Revenue Code Section 6320 or 6330 issued to petitioner on October 31, 2022, for petitioner's corporate income tax liabilities for taxable years 2014, 2015, 2016 and 2017, upon which this case is based, are sustained in full.