Opinion
26391-21S
03-21-2024
RONALD JAY CLARK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On March 5, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. By Order served March 7, 2024, the Court directed petitioner to file an objection, if any, to respondent's Motion. To date, no objection has been filed. However, on March 20, 2024, respondent filed a Status Report, advising the Court that petitioner Ronald Jay Clark died on March 1, 2024. A copy of the decedent's death certificate is attached to respondent's Status Report.
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 the decedent and afford them an opportunity to take whatever action may be necessary to protect their interests.
Upon due consideration of the foregoing, it is
ORDERED that the caption of this case is amended to read: "Ronald Jay Clark, Deceased, Petitioner v. Commissioner of Internal Revenue, Respondent." It is further
ORDERED that, on or before April 22, 2024, 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 the decedent Ronald Jay Clark. It is further
ORDERED that action on respondent's Motion to Dismiss for Lack of Jurisdiction shall be held in abeyance pending further direction by the Court.