Opinion
10703-23
08-02-2023
HENRY L. GOODMAN & JOAN D. GOODMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
On June 23, 2023, the Court received on behalf of petitioners a letter, attached to which was a copy of a notice of deficiency dated April 3, 2023, issued to petitioners with respect to the 2020 taxable year. To protect petitioners' statutory time period within which to begin a case, the Court filed that letter as a petition to commence this case at Docket No. 10703-23. On July 17, 2023, the Court issued an Order directing the filing of a Ratification of Petition on or before August 31, 2023. On July 31, 2023, the Court then received on behalf of petitioners a further submission, entitled a Motion To Dismiss, indicating that petitioners preferred to work administratively through the Internal Revenue Service to resolve the 2020 tax matters, and had apparently done so, rather than to continue with the instant Court proceeding.
Accordingly, it appearing that petitioners do not intend to file a Ratification of Petition as directed in the Court's Order, it is
ORDERED that petitioners' just-referenced Motion To Dismiss is granted in that this case is dismissed for lack of jurisdiction on the ground that the petition had not been ratified.