Opinion
26368-22
02-07-2023
NORBERTO DEL RIO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Lewis R. Carluzzo, Chief Special Trial Judge.
There being nothing in the petition that gives rise to a justiciable issue, it is
ORDERED that this case is dismissed because petitioner has failed to state a claim upon which relief can be granted. It is further
ORDERED that respondent's motion to dismiss, filed January 25, 2023, is moot.
Petitioner's attention is invited to I.R.C. section 6673(a). If it appears to the Court that a taxpayer's position in a proceeding before the Court is frivolous or groundless, then the Court can impose a penalty (not to exceed $25,000) on that taxpayer. Petitioner is advised that it appears to the Court that the position he has taken in this case is frivolous or groundless. No penalty will be imposed at this time. However, future submissions advancing a frivolous or groundless position will result in the imposition of a penalty.