Opinion
29492-21L
08-23-2023
SHOW OF FORCE, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
The petition in this case was filed on August 31, 2021. That petition was not properly executed in that it does not bear the original signature of someone who has the legal capacity to execute the petition on behalf of petitioner or of counsel admitted to practice before the Tax Court, as required by the Tax Court Rules of Practice and Procedure.
On October 3, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not properly executed. On July 10, 2023, respondent filed a First Supplement to his motion. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented, is granted. It is further
ORDERED that this case is dismissed for lack of jurisdiction on the ground that the petition was not properly executed.