Opinion
13195-22S
10-07-2022
MICHAEL D. BATTLES & JACQUELINE P. BATTLES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 26, 2022, respondent filed a motion to dismiss for lack of jurisdiction as to Michael D. Battles on the ground that no notice of deficiency or notice of determination for tax year 2018 was issued to Michael D. Battles that would permit him to invoke the jurisdiction of this Court. Although the Court directed petitioners to file an objection, if any, to respondent's motion, petitioners have not done so.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case relating to petitioner Michael D. Battles is dismissed for lack of jurisdiction and is deemed stricken from the Court's record. It is further
ORDERED that the caption of this case is amended to read: "Jacqueline P. Battles, Petitioner v. Commissioner of Internal Revenue, Respondent".