Opinion
7225-24S
06-28-2024
THOMAS R. BREWER & CAROL L. BREWER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On June 27, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Carol L. Brewer and To Change Caption. As grounds for his motion, respondent asserts that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to Ms. Brewer's 2018 tax year. To ensure an adequate opportunity for petitioners to be heard notwithstanding a representation by respondent that there is no objection to the granting of the motion, it is
ORDERED that, on or before July 19, 2024, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file a timely objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to Carol L. Brewer. The Court will take appropriate action on the motion following the period for objection.
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