Opinion
20363-23
03-18-2024
ROBERT MARNELL & SHANNON MARNELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On December 21, 2023, correspondence from or on behalf of petitioners was filed as an imperfect petition to commence the above-docketed case. By Order served December 27, 2023, the Court directed petitioners to file an Amended Petition for consideration. However, no Amended Petition has been received from petitioners. Petitioners are reminded that the Tax Court is entirely separate from the Internal Revenue Service (IRS).
In view of the foregoing, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction on the ground that petitioners failed to file a proper Amended Petition.
Petitioners are advised that the Court, on its own motion, will consider reinstating this case if, within 30 days from the date of service of this Order, a properly signed amended petition is filed. Forms are available on the Court's website, www.ustaxcourt.gov, by choosing "eFiling & Case Maintenance", then by clicking on "Case Related Forms". However, the Court also warns that the case could later be dismissed AGAIN if jurisdiction is shown to be lacking for reasons other than the lack of an Amended Petition.