This paragraph from the decision to dismiss says it all….

[6] Thus, the affidavit discloses that on December 10, 2021 a notice of objection was served. That date was more than fifteen years beyond the last date (November 22, 2006) for timely serving of a notice of objection and fourteen years beyond the last date (November 22, 2007) for seeking an extension of time for timely serving of the notice of objection.

I’ve written about this before, the Tax Court is a statutory court and does not have discretion to provide equitable relief no matter how justified it may be (in this case we have no reason for the delay one way or another). This was a waste of the court’s and the appellant’s time.