Opinion
3938-23
12-28-2023
MELISSA BLAIR & ERIC BLAIR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge.
This case is on the calendar of the Court's March 18, 2024, trial session in Philadelphia, Pennsylvania. On December 22, 2023, respondent filed a Motion to Dismiss Petitioner Eric Blair for Lack of Jurisdiction (Doc. 9). Respondent moves that petitioner Eric Blair be dismissed for lack of jurisdiction upon the ground that no statutory notice of deficiency, as authorized by I.R.C. § 6212 and required by I.R.C. § 6213(a) to form the basis for a petition to this Court, has been sent to petitioner Eric Blair with respect to taxable year 2020, nor has respondent made any other determination with respect to petitioner Eric Blair's taxable year 2020 that would confer jurisdiction over petitioner Eric Blair on this Court.
Upon due consideration, it is
ORDERED that, on or before January 18, 2024, petitioners shall file an objection or response to respondent's Motion to Dismiss for Lack of Jurisdiction. Petitioners are warned that failure to comply with the terms of this Order may result in the Court granting respondent's motion and dismissing petitioner Eric Blair from this case.