Opinion
8884-20S
03-24-2022
ORDER AND DECISION
Diana L. Leyden, Special Trial Judge
On February 28, 2022, respondent filed with the Court a Motion To Dismiss For Failure To Properly Prosecute (motion to dismiss).
This case was called from the calendar for the remote Trial Session of the Court at San Francisco, California on March 21, 2022. This case was recalled March 22, 2022. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that respondent's motion to dismiss, filed February 28, 2022, is granted. It is further
ORDERED and DECIDED that petitioner is not entitled to relief under I.R.C. § 6015 (b), (c), or (f) for the taxable year 2016.