Opinion
13453-20
08-30-2021
Old Paris Landing Holdings, LLC, MidAmerica Property Holdings, LLC, A Partner Other Than the Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On November 4, 2020, a petition was filed at Docket No. 12887-20 based upon the same notice of final partnership administrative adjustment as forms the basis for this case. Subsequently, on December 29, 2020, petitioner filed the petition in this case.
Under section 6226(b)(2) and (4), if more that one partnership action case is commenced with respect to a partnership for the same taxable year, the first case commenced goes forward and subsequent cases are dismissed.
Premises considered, it is
ORDERED that, on or before September 20, 2021, the parties shall show cause why this case should not be dismissed for lack of jurisdiction on the ground a timely petition was previously filed with respect to the same Notice of Final Partnership Administrative Adjustment as forms the basis for this case.