Opinion
245-19
06-10-2024
YP LLC, PARTNERSHIP, CERBERUS YP DIGITAL LLC, YP HOLDINGS MANAGEMENT LLC, YP EQUITY INVESTORS, LLC, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Christian N. Weiler, Judge.
On June 6, 2024, the parties filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the tax matters partner (TMP) has filed a petition within the 90-day period set for in section 6226(a), with respect to the same notices of Final Partnership Administrative Adjustment (FPAAs) in this case, and pursuant to section 6226(b)(1) a partner - other than the TMP - may file a petition only if the TMP does not file a petition.
In consideration of the foregoing, it is
ORDERED that the parties' Motion to Dismiss for Lack of Jurisdiction, filed June 6, 2024, is granted and this case is dismissed for lack of jurisdiction.