Opinion
10457-21
07-05-2022
SILVER RUN HOLDINGS, LLC, SILVER RUN PARTNERS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case is currently calendared on the Court's Atlanta, Georgia, trial session, scheduled to begin September 12, 2022.
On June 30, 2022, the Commissioner filed a motion to dismiss for lack of jurisdiction on the ground that this case is duplicative in that the petitioner previously filed a petition challenging the same Final Partnership Administrative Adjustment. We will direct the petitioner to file a response. Accordingly, it is
ORDERED that, on or before August 1, 2022, petitioner shall file a response to the Commissioner's motion to dismiss for lack of jurisdiction.