DISMISSED WITH PREJUDICE: April 8, 2026
CBCA 8801
PINNACLE FEDERAL ADVISORY, LLC,
Appellant,
v.
DEPARTMENT OF THE TREASURY,
Respondent.
John R. Tolle of Baker, Cronogue, Tolle & Werfel, LLP, McLean, VA, counsel for
Appellant.
The case caption as the decision prints it. Every word is kept; the rule the Board draws around it is not text, so it is not repeated here.
Gregory Matherne, Office of Chief Counsel, Internal Revenue Service, Department of the Treasury, Washington, DC, counsel for Respondent.
BEARDSLEY, Board Judge (Chair).
Order
On April 7, 2026, the parties filed a joint motion to dismiss this appeal, representing that they have settled the underlying dispute. The parties’ motion is granted. This appeal is DISMISSED WITH PREJUDICE.
Erica S. Beardsley
Board Judge
This is a verbatim capture of the text layer of the Board's own document in Pinnacle Federal Advisory, LLC, CBCA 8801. Nothing is summarized or reworded, and the sections run in the order the Board wrote them. What the page shows and the text does not repeat is the pagination furniture: the page numbers and the rules the Board draws around its caption and under its signatures. The signatures are set back into the columns the Board prints them in, each judge under the name he or she signed, and the typed copy of that name the page carries beneath each signature is not repeated.