Opinion
24533-21S
04-13-2022
JOSE RANGEL & JAEL ALVARADO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge.
On November 5, 2021, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Jael Alvarado, on the ground that no statutory notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner Jael Alvarado with respect to taxable year 2017, nor had respondent made any other determination with respect to Jael Alvarado's tax year 2017 that would confer jurisdiction on this Court, as of the date the petition herein was filed. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so. Accordingly, it is
ORDERED that respondent's Motion To Dismiss For Lack of Jurisdiction as to Jael Alvarado is granted. This case is dismissed for lack of jurisdiction as to Jael Alvarado, and references in the petition to Jael Alvarado are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Jose Rangel, Petitioner v. Commissioner of Internal Revenue, Respondent".