Opinion
5659-22S
12-08-2022
THOMAS LYON OWENS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On December 7, 2022, petitioner and respondent filed responses to the Court's Order served November 7, 2022. Both stated in their responses that they have no objection to dismissal for lack of jurisdiction of so much of this case relating to a notice of determination concerning collection action with respect to petitioner's 2017 tax year on the grounds that no such notice sufficient to confer jurisdiction upon this Court was issued to petitioner.
Also on December 7, 2022, in order that he might prosecute this case on petitioner's behalf, Henry Charles Owens filed a Motion to Be Recognized as Next Friend. Mr. Owens states therein that respondent has no objection to his motion.
Upon due consideration of the foregoing, it is
ORDERED that, on the Court's own motion, so much of this case relating to a notice of determination concerning collection action is dismissed for lack of jurisdiction. It is further
ORDERED that the above-referenced Motion to Be Recognized as Next Friend is granted. It is further
ORDERED that the caption of this case is amended to read: "Thomas Lyon Owens, Henry Charles Owens, Next Friend, Petitioner(s) v. Commissioner of Internal Revenue, Respondent".