Warlock Enters. v. Comm'r of Internal Revenue

• Decision Date: 23 September 2022
• Docket Number: 20634-22
• Parties: WARLOCK ENTERPRISES, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
• Court: U.S. Tax Court

WARLOCK ENTERPRISES, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

No. 20634-22

United States Tax Court

September 23, 2022

ORDER OF DISMISSAL

Lewis R. Carluzzo, Chief Special Trial Judge

There being nothing in the petition that gives rise to a justiciable issue, it is

ORDERED that this case is dismissed because petitioner has failed to state a claim upon which relief can be granted.

Petitioner's attention is invited to I.R.C. section 6673(a). If it appears to the Court that a taxpayer's position in a proceeding before the Court is frivolous or groundless, then the Court can impose a penalty (not to exceed $25,000) on that taxpayer. Petitioner is advised that it appears to the Court that the position it has taken in this case is frivolous or groundless. No penalty will be imposed at this time. However, future submissions advancing a frivolous or groundless position will result in the imposition of a penalty.

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