Opinion
17004-16
11-06-2023
JOSEPH W. BILOTTA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
On January 13, 2023, respondent filed a Motion for Continuance of Trial (Doc. 77) informing the Court that petitioner passed away after the Petition in his case was filed. Since then, respondent has filed multiple status reports.
In accordance with the principles established in Nordstrom v. Commissioner, 50 T.C. 30 (1968), this Court must give proper notice of this proceeding to the heirs at law of petitioner and afford them an opportunity to take whatever action may be necessary to protect their interests. Upon due consideration, it is hereby
ORDERED that, on or before December 4, 2023, respondent shall file a report setting forth, based upon and following a reasonably diligent and good faith search conducted by respondent, the names, mailing addresses, and telephone numbers of the heirs at law of Joseph W. Bilotta. Respondent shall also attach to the report a copy of Joseph W. Bilotta's death certificate.