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Nasrallah v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 14383-19 (U.S.T.C. Nov. 16, 2022)

Opinion

14383-19

11-16-2022

CHRIS M. NASRALLAH, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL AND DECISION

Elizabeth Crewson Paris Judge.

This case was calendared for trial at the November 9, 2020, Dallas, Texas Trial Session of the Court. On October 16, 2020, respondent filed a Motion for Continuance at docket entry number 11, indicating that petitioner died October 8, 2019, after the petition was filed in this case. On October 19, 2020, the Court continued the case off of the November 9, 2020, Dallas, Texas Trial Session of the Court, at docket entry number 12, and ordered the parties to file a report as to any probate proceedings, fiduciaries authorized to act on behalf of petitioner's estate, and any known heirs-at-law by January 22, 2021.

On January 22, 2021, respondent filed a status report informing the Court that petitioner's mother Antoinette Nasrallah indicated that: 1) petitioner had no assets, 2) she had no plans to file a probate in his estate and 3) there is no fiduciary or family member has been authorized to litigate on behalf of petitioner's estate, at docket entry number 14. In respondent's report, he states that deceased petitioner's counsel was gathering information as to if there were any heirs-at-law.

On May 11, 2022, the Court ordered the parties to update the Court as to any probate proceedings, fiduciaries authorized to act on behalf of petitioner's estate, and to provide the Court with the status as to any known heirs-at-law by June 30, 2022, at docket entry number 16. On June 30, 2022, respondent filed a report with the Court indicating that per deceased petitioner's counsel there was no updated knowledge of any fiduciaries authorized to act on behalf of petitioner's estate, at docket entry number 19. In respondent's report, deceased petitioner's counsel indicated that the only heirs-at-law were deceased petitioner's former spouse, Jacqueline A. Lowery, minor surviving children and two (2) sisters, one of which is named Christeen Nasrallah, and that all above-mentioned heirs-at-law do not wish to participate in this case. On October 7, 2022, respondent filed a Motion to Dismiss for Lack of Prosecution. Respondent is conceding the deficiencies and penalties in this case.

Giving due regard to respondent's representations and for cause, it is

ORDERED that respondent's Motion to Dismiss for Lack of Prosecution is granted, and this case is dismissed for lack of prosecution. It is further

ORDERED and DECIDED that there are no deficiencies in Federal income tax due from petitioner for the taxable years 2013 and 2014. It is further

ORDERED and DECIDED that there are no penalties under Internal Revenue Code sections: 6651(a)(1), 6651(a)(2), and 6662(a), due from petitioner for the taxable years 2013 and 2014.


Summaries of

Nasrallah v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 14383-19 (U.S.T.C. Nov. 16, 2022)
Case details for

Nasrallah v. Comm'r of Internal Revenue

Case Details

Full title:CHRIS M. NASRALLAH, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Nov 16, 2022

Citations

No. 14383-19 (U.S.T.C. Nov. 16, 2022)