Opinion
23070-22L
03-01-2023
ALLAN J. ROLNICK & HEIDI NELSON ROLNICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On December 15, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Petitioner Heidi Nelson Rolnick, on the ground that no notice of determination pursuant to section 6320 and/or 6330 of the Internal Revenue Code had been sent to petitioner Heidi Nelson Rolnick with respect to the taxable years 2011 and 2013, nor had respondent made any other determination with respect to Heidi Nelson Rolnick's tax year 2011 and 2013 that would confer jurisdiction on this Court, as of the date the petition 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 Petitioner Heidi Nelson Rolnick is granted. This case is dismissed for lack of jurisdiction as to Heidi Nelson Rolnick, and references in the petition to Heidi Nelson Rolnick are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Allan J. Rolnick, Petitioner v. Commissioner of Internal Revenue, Respondent".