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Wrigley v. Comm'r of Internal Revenue

United States Tax Court
Mar 23, 2023
No. 19796-21 (U.S.T.C. Mar. 23, 2023)

Opinion

19796-21

03-23-2023

HUGH N. WRIGLEY & DIANA J. CRAWFORD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Mark V. Holmes Judge

This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. We continued it at the parties' request because petitioners' counsel spotted a TEFRA procedural tangle that respondent wanted to analyze. Both parties now agree that the 2016 and 2017 tax years need to be dismissed for lack of jurisdiction for making partnership determinations in a notice of deficiency sent to individual partners. It is therefore

ORDERED that the parties' February 17, 2023 motion to dismiss is granted, and this case is dismissed for lack of jurisdiction as to tax years 2016 and 2017.


Summaries of

Wrigley v. Comm'r of Internal Revenue

United States Tax Court
Mar 23, 2023
No. 19796-21 (U.S.T.C. Mar. 23, 2023)
Case details for

Wrigley v. Comm'r of Internal Revenue

Case Details

Full title:HUGH N. WRIGLEY & DIANA J. CRAWFORD, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Mar 23, 2023

Citations

No. 19796-21 (U.S.T.C. Mar. 23, 2023)